Aer Lingus Submission to Aviation Recovery Taskforce

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Aer Lingus Submission to Aviation Recovery Taskforce – 17 June 2020

As agreed at the first meeting of the Aviation Recovery Taskforce on 12 th June, the following submission reflects the Aer Lingus view on the priority measures which should be implemented by the Government.

The broader economic shock from the Covid-19 crisis is profound and unprecedented. As an island economy with a huge reliance on connectivity and mobility, Ireland needs its airlines and airports to be ready to recommence operations.

Air transport will be an early enabler of economic recovery, allowing people, goods and investment to flow back into the economy. This will be critical to the recovery of the Irish economy.

Given the depth of the crisis in aviation, Aer Lingus believes that the Aviation Recovery Taskforce has a requirement to consider a two pronged approach which separates the immediate term restart priorities from shorter / medium term priorities.

Immediate term

Aer Lingus believes that the Taskforce should recommend that the Government act on the invitation of the European Commission to commence a process of re-opening unrestricted cross- border movement within the Union. In order to do so, the Taskforce should recommend to Government that the following actions be taken on an immediate basis:

 Set a date for the lifting of the 14 day quarantine period for inbound passengers from states of similar containment – the effective date of the lifting of the quarantine period should be no later than 29 th June

 The appropriate easing of the Government’s general advisory recommending against non-essential international travel

 Finalise and issue the Code of Practice by 19th June for implementation by end of June - this will allow industry stakeholders to implement the Code of Practice measures

 Ensure that travel insurance with appropriate cover is available in the market place

We suggest that text along the following lines be communicated to the Government prior to the meeting of the Cabinet scheduled to be held on 19 th June:

“The Aviation Recovery Taskforce had its first meeting on 12 th June.

At this meeting the members unanimously decided to make the following immediate recommendations to Government:

1. Quarantine Period: That the Government make an immediate announcement of the removal of the 14 day quarantine period applicable to inbound passengers from States with similar containment. The effective date of the lifting of the quarantine period should be no later than 29 th June.

The taskforce noted in particular the direction provided on 11 th June by European Commissioner for Home Affairs, Ylva Johansson in calling upon Members States to lift all border restrictions by 15 th June.

Steps have already been taken by most European Union Member States to ease travel restrictions. Ireland is significantly behind other Member States in this regard despite having equivalent or better success in containing Covid-19.

2. Travel Restrictions: Consistent with the European Commission’s request, that the Department of Foreign Affairs and Trade announce the appropriate easing of the Government’s general advisory recommending against non-essential international travel.

3. Code of Practice: That the Department of Transport, Tourism & Sport finalise and issue by no later than 19 th June the Code of Practice which represents the proposed Irish implementation of the EASA/ECDC - COVID-19 Aviation Health Safety Protocol. The airlines and airports on the Taskforce confirmed their commitment to implementation of the Code of Practice to facilitate a resumption of services.

4. Travel Insurance: That the Government take steps to ensure that travel insurance with appropriate cover is available in the market place.

The Taskforce emphasises the critical urgency in implementing these recommendations on an immediate basis.

The Taskforce will meet again on 19 th June to consider whether there are further interim recommendations that should be issued.”

Short / Medium term

Following the issuing of the immediate recommendations set out above, Aer Lingus believes that the balance of the Taskforce’s work should focus on the following:

 In line with the guidance in the EASA/ECDC - COVID-19 Aviation Health Safety Protocol regarding the temporary nature of the recommendations within it, the Taskforce should recommend that the Code of Practice should be kept under constant review and adjusted appropriately in accordance with progress in containing Covid-19.

 Recognising that the aviation sector is experiencing sustained and unprecedented decimation of revenues, the Taskforce should consider recommending the introduction of a range of supports for further cost alleviation by Government and local authorities, including:

o Continuation of the Temporary Covid-19 Wage Subsidy Scheme o Removal of PRSI contributions for employees still being paid by affected businesses for whom no income support is being received o Removal or expanding the earning caps for the Wage Subsidy Scheme where business activity to support these employees has clearly declined as a result of the crisis o Alleviation of local authority rates for direct aviation related businesses by relevant local authorities

 In addition to these direct initiatives, several countries have introduced tax measures or alleviations to further support corporate cash flows. For example, in the UK it is possible to carry back projected losses from the current year to a prior year before the current

financial year has ended, thereby eliminating the requirement for preliminary tax payments or facilitating the repayment of previous preliminary payments made on account. A similar initiative in Ireland on Corporation Tax could be introduced.

 The introduction of cost alleviation measures that can enable restart and recovery of operations including in relation to aeronautical and airport charges.

 The introduction of support to be provided directly to airports if alleviation measures are put in place in relation to aeronautical and airport charges.

 Avoiding the introduction of any new charges or taxes whilst the industry is in recovery mode.

 Ireland lags significantly behind the larger EU economies in providing liquidity support to larger business entities despite this being permitted in the newly issued guidelines on the EU’s temporary state aid framework. The Taskforce should encourage the Irish Government to follow the lead taken in countries like the UK, France, Spain, Germany etc. in ensuring supports for Government backed liquidity are enabled. The most appropriate form of support would be guarantees, credit lines or underpins for favourable interest rates/margins in line with pre-Covid levels.

 The waiver of airport slot rules has enabled airlines to de-risk the reduction in their schedules without penalising their ability to resume and retain use of slots. It is critical that the Government continues to support the extending of the waiver of the 80:20 slot use-it or lose-it rule in the worldwide slot guidelines for the winter season.

 The lifting of onerous planning restrictions associated with the operation of the new Northern Runway at Dublin Airport which currently risks creating a reduction in capacity at Dublin airport and impeding any recovery. The Northern Runway at Dublin Airport currently remains subject to planning constraints to control the frequency of night flights at the airport. The restrictions effectively reduce capacity at Dublin Airport and would impede recovery capability. The planning restrictions provide that the average number of night time aircraft movements at the airport shall not exceed 65 flights per night between 2300 hours and 0700 hours, which is insufficient.

 The National Aviation Policy promotes the development of Dublin airport as an international hub. This policy was supported by the hub infrastructure plans in the Capital Investment Programme (CIP) proposed by Dublin Airport in 2018. These proposals were subsequently approved and recognised by the Commission for Aviation Regulation (CAR) in their final price determination issued in October 2019 for the 2020-2024 regulatory period. Given the likely timeframe in which to achieve a recovery in passenger demand, there is a risk to the following:

(i) competitiveness of Dublin Airport should airport charges increase; and (ii) the ability to facilitate growth without appropriate hub and other capacity related infrastructure, should delivery of the capital programmes be delayed or shelved.

Therefore, in order to mitigate these risks, the Taskforce should recommend that the Government consider the development of some mechanism which would allow airports to deliver planned infrastructure programmes in full and on time without increasing airport charges.

Aer Lingus is available to expand on any element of this submission as required.

Subject A Risk based approach to establishing air-bridges Aviation Recovery Date 23 June 2020 Job No/Ref Task Force

1 Introduction

Ireland is rightly concerned about re-establishing the presence of Covid-19 in the State through the importation of the virus via in-bound passengers. In response it is applying uni-dimensional approaches in the form of border closures with quarantine measures.

A multi-dimension approach recognises that the risk will differ between flights due to factors including, but not limited to, the passengers’ health status, departure country’s C-19 status and measures taken on board the aircraft and in transfer airports. Adopting a risk-based approach can enable sufficiently flexible approaches that the economic effects of the uni-dimensional approach can be safely mitigated with evidence, using a scientific approach.

Adopting a risk-based approach to the establishment of air-bridges (or travel bubbles) allows for the management of the inbound Covid-19 risk and allows partnerships with other similarly managed economies to rebuild a safe, connected society.

Arup has established a risk-based model that allows for in-bound Covid-19 risk management commensurate to the risk. This approach does not open in-bound flights unilaterally with a risk rating, but rather knowingly only connects low-risk countries, and thus with less onerous passenger controls.

2 The model

Currently there is no universally accepted capability to assess an individual’s risk level upon arrival at an airport. A risk model must assess the total passengers’ journey risks that may contribute to a potential Covid-19 import. These components have been identified as the:

1. departing country

2. departing airport

3. aircraft

4. passengers

5. transit/transfer point(s)

Collectively the journey or arriving flight’s risk level can be determined. Once determined, mitigation measures can be applied appropriate and commensurate to the risk and therefore negating the need for the blanket approach as is currently in place. The measures can be applied on departure and/or arrival as is appropriate to the jurisdiction, mutual recognition of measures and risk-factor e.g: if ‘health during flight’ changes en-route, measures have to be applied on arrival.

E:\USERS\RKEANE\APPDATA\LOCAL\MICROSOFT\WINDOWS\INETCACHE\CONTENT.OUTLOOK\3GZ6VB27\IRISH AVIATION TASK FORCE - A RISK BASED APPROACH TO BOARDER OPENING - ARUP.DOCXC:\USERS\CONOR.HOEY\DESKTOP\IRISH AVIATION TASK FORCE - A RISK BASED APPROACH TO BOARDER OPENING CH24062020.DOCXHTTPS://ARUP- MY.SHAREPOINT.COM/PERSONAL/TERRY_LEE-WILLIAMS_ARUP_COM/DOCUMENTS/COVID/IRISH AVIATION TASK FORCE - A RISK BASED APPROACH TO BOARDER OPENING CH23062020.DOCX

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Subject A Risk based approach to establishing air-bridges

Aviation Recovery Date 23 June 2020 Job No/Ref Task Force

This model is illustrated as follows:

The model allows for different risk-factors to be considered e.g: removal of ‘testing status’ as a risk-factor and weighting to be applied subject to the relative importance of components to the State.

It is acknowledged that Governments’ confidence in the measurement of the risk and the application of the mitigation measures is critical to its success. With the exception of passengers’ travel history and test status, all other information will be sourced from governments, airports and airlines so are inherently credible and/or can be validated independently. The application of mitigation measures can also be validated independently.

Data associated with passengers’ travel history and test records will be more difficult to incorporate due to the varied formats on which information is currently collected e.g: paper-based declarations, state-level tracking of individuals’ movements. Additionally, there is no universal accreditation programme for testing standards and test result reporting. This risk associated with this information challenge can be overcome in the short term with the application of additional mitigation measures applied to flights. In the longer term this will be superseded by a universally accepted ‘health passport’ and/or uniform data collection and validation processes such as that being developed by IATA for travel history records.

By introducing a risk-based approach, the State can both incentivise other countries to adopt the stringent data controls and readily determine whether other countries are good actors in the system. By publishing on its communications channels, the Government can also make it easy for potential passengers, airlines and travel agents to understand with total clarity what ports are open for low- barrier business, and which still require existing controls including quarantine. This then moves the pressure from the Government to the destination states to comply in order to move from the green list from the red list.

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Subject A Risk based approach to establishing air-bridges

Aviation Recovery Date 23 June 2020 Job No/Ref Task Force

3 The Tool

Arup has a baseline/’manual’ tool developed already but further development of the platform may be needed subject to the frequency of use and expectations associated with interface with data- sources.

4 Proposal

The Taskforce consider the adoption of a Risk Based approach to developing air-bridges and facilitating the release of quarantine restrictions. Arup are will be available to discuss this concept further, including the Air-Bridge Risk Assessment Model and Tool which has been developed.

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ASL Aviation Holdings Written Submission to the Taskforce for Aviation Recovery

Introduction ASL Aviation Holdings DAC is an Irish aviation services company with global operations on 6 continents. Based in Swords, County Dublin, the ASL Group has 6 airlines including 4 in the European Union in Ireland, Belgium, France and Hungary. The Group also has airlines in South Africa and Thailand. The ASL Group has a fleet of 130 aircraft, ranging from the Boeing 747 to the ATR turbo prop. The Boeing 737 is the backbone of the fleet and ASL operates the largest fleet of B737 freighters in Europe. An agreement with Boeing has also been announced for a further 10 Boeing 737 converted freighters and 10 options. ASL Aviation Holdings has 2,650 employees, with more than 500 in ASL Airlines Ireland. ASL’s Irish airline is based in Dublin and has its maintenance base in Shannon Airport, County Clare. ASL Airlines Ireland has a fleet of 38 aircraft including ATR turbo props, Boeing 737’s and widebody Airbus A300-600 and A330-200/300 freighters. ASL’s freighters have operated throughout the COVID-19 pandemic and have so far carried more than 2 billion individual facemasks and pieces of PPE from China to Europe. These were then distributed throughout Europe on ASL’s European fleet.

WHAT ARE THE SHORT-TERM ACTIONS NEEDED? WHAT IS URGENT AND IMPORTANT RIGHT HERE AND NOW? Cargo Airlines The European Commission and Member State governments, including the Government of Ireland, must include cargo airlines in plans to save and revitalise the aviation industry. This is especially true in Ireland where cargo airlines provide an essential service that cannot be replaced by road, rail or in terms of time, by marine transport. Cargo airlines have continued flying and have been experiencing high load factors during the pandemic. However, this was all ‘pandemic’ related transport of medical supplies and equipment and demand is already falling off quickly.  Cargo airlines, in long-term contracts could not, contrary to reports, inflate freight rates. However, cargo airlines suffered huge cost increases, including operations costs, in their efforts to keep flying.  Cargo airlines do not fly point to point as passenger airlines do. Crews position from their base to meet aircraft down the line and then position back to base a week later for their regulated rest period. With almost all passenger flights grounded, crews could not position, and other more expensive ways had to be employed to ensure the continued operation. This included chartering aircraft to position crews and paying significantly inflated hotel and catering charges.  As the requirement for special pandemic flights reduces, cargo airlines are now facing major financial problems as the severely damaged economy impacts demand. It is essential therefore that cargo airlines are included in all discussions and plans for European aviation recovery, including direct State Aid and State loans.

Crews There needs to be an immediate relaxation of security and health measures for operating crews, positioning crews and mechanics/engineers who are undertaking travel throughout Europe to maintain essential cargo operations. Crews are facing medical checks and the potential of quarantine even though they are complying with EU cargo guidelines that allow them to remain on their flight decks during turnarounds, meaning they have not actually entered a country. Crews on overnight rest are being isolated in their hotel rooms and limited access to food and no access to exercise in some Member States. The Irish Government could support cargo crews by raising this in DG-Move and EASA and seeking a coordinated system that supports the health and safety of crews during rest periods without causing stress and discomfort.

Quarantine As the Irish Government looks at speeding-up the exit from lockdown, it is imperative that the 14-day quarantine for air passengers arriving in Ireland is ended.  This is an absolute necessity to stimulate economic recovery  The retention of the quarantine measure will have a massive impact on Irish airlines and will lead to job losses and potential airline closures.  Removal of the quarantine measure is also necessary for the social wellbeing of the population With borders opening in Europe, the removal of the quarantine measure in Ireland must be one of the measures announced by the Government for the next lockdown exit phase, effective 29th June.

Aircraft are equipped with high-efficiency particulate air (HEPA) filters. These are a very high-intensity system of fibres that air runs through, filtering out an incredible amount of contaminants including dust, bacteria, moisture and any sort of contamination that could potentially harm or create an atmosphere in the cabin or the cockpit that could harm the passengers or the crews. The material in them is much closer together compared to cheaper air filters, and that makes it very difficult for biological elements to penetrate them.

These filters make air travel far safer than other forms of public transport including buses, trams, taxis and trains, all of which are currently operating in Ireland.

In European terms there is a requirement for co-ordinated Member State action towards lifting travel bans, lockdown and quarantines measures. These are currently different for every country and changing constantly, making planning difficult and complicating travel or making it impossible.

Air travel is a friend, not an enemy. It will stimulate the economy, save airlines and thousands of jobs and will not increase the risk of contracting COVID-19.

Recovery plans should be agreed on the widest possible basis and with a harmonised approach, so that the same principles are applied at origin and destination wherever they may be. The possibility, for example, that Irish people will be able to travel to Spain and Portugal from July 1st with no quarantine requirements, but will have to self- isolate for 14 days when they return, is unworkable for the aviation industry, the Irish economy and social wellbeing. It is essential that all European states adhere to EASA/ECDC guidance so that airline operations can resume as soon as possible. Once these guidelines are being followed, aviation should be allowed to return to normal operations, insofar as this is possible given the huge financial losses all airlines, passenger and cargo have suffered and continue to suffer.

State Aid and Competition The recovery of the aviation industry, passenger and cargo, is essential to the economy in Ireland and the European Union. This will require significant actions by Member States including financial aid by way of investment, grants, loans and guarantees However, Member State governments, including the Government of Ireland, must attach strict conditions to any support packages. These conditions must protect the principles of equal opportunities and non-discrimination. In order to prevent undue distortions of competition, State Aid cannot benefit one airline at the expense of another. Beneficiaries must not engage in aggressive commercial expansion financed by State Aid. Ireland must ensure, nationally and in Europe, that there is equity in state support for airlines across Europe. This means equity within each Member State as well as a coordinated approach and equity across the EU. State funding to date seems to be aimed almost exclusively at major airline groups and national carriers with a ‘legacy state-owned’ background. This completely distorts competition, and this will impact the Irish economy. European airlines receiving state support cannot be precluded from operating into Ireland and they currently operate in many of the markets as Irish airlines. These country by country state support schemes must be re-balanced so that they do not distort competition. While we argue for airport support elsewhere in this paper, it is also essential that airport charges to not increase. Airports seeking to recover could seem abnormally high increases in charges to airlines, and this needs to be blocked by national and European regulators. Government action is especially required where airports are not subject to a regulated charging system.

Airlines are bleeding money; jobs are being lost and it will be a struggle to restart operations. At a time when airlines face closure or a period of years before full recovery, they cannot afford increased charges.

The Irish Government and the EU should ensure that airports are funded for recovery without the need to place an extra burden on airlines that cannot afford to pay. Penalising airlines to support airports will inevitably see both suffer more. The Irish Government should consider a support package for Irish airlines by proposing an extraordinary temporary broadening of the scope of PSO routes with the European Commission to allow many more intra-European cross border routes to be re-opened.

WHAT IS NEEDED FOR THE MEDIUM TERM, 3-6 MONTHS?

Ongoing Tracing The removal of quarantine measures is an immediate requirement, but it may be several months before passenger load factors start to show signs of a return to normal. It is essential that airlines, airports, and public authorities, do everything possible to prevent a COVID-19 infected person from travelling and to track them if they do. The areas of biometrics, health controls, IT apps and sophisticated reservation systems to better track the passengers to ensure health protection will require large financial investments for both airlines and airports and Member States should consider this a national investment. Aviation will not continue as usual, therefore exceptional measures are needed including a waiver of ATC charges and an extension to the slot waiver into W2020/21 season.

There is also a need for flexibility in ongoing or planned policy issues. Reference Period 3 and the traffic risk sharing mechanism should be addressed, as airlines cannot pay for essential services they are not using.

Irish Support in Europe is required to confirm agreement that 2020/21 be considered as extraordinary years and we should return to normal regulations in 2022. from 2022 onwards.

The EU Recovery Plan (Next Generation EU) under the Green Deal needs to include aviation as a basic sector in the foundation of the economic recovery of Europe, with adequate funding from Member States. Tourism is very important to Ireland, but transport is at its foundation. While tourism must be supported, it will rely on a functioning aviation sector. Support for aviation should therefore take account of the resulting benefit to tourism. Regional airlines and regional airports play a crucial role in developing local economies and the cohesion of the regions. Shannon, Knock, Kerry and Waterford are independent regional airports. These airports have seen a massive decline in traffic and must be supported as airlines start to build up services and re-open routes. The temporary extension of PSO routes would play a big role in supporting Ireland’s regional airports and economies, as well as airlines. Ireland should promote the design of a targeted route support or PSO funding programme addressing national and international routes that do not have a viable alternative by land. This will be critical to regional business and especially tourism. Regulatory capex timing: in the normal course of business, airports are exposed to major capital expenditure requirements on foot of regulatory decisions. Specifically, European/Irish airports, including regional airports, are currently having to spend multi-million-euro amounts, from their own funds, on new hold baggage screening equipment (ECAC Standard 3 explosive detection systems) in line with EC Implementing Regulation 2015/1998. Faced with the Coronavirus-caused collapse in revenue and cash reserves, regional airports will be unable to fund such major expenditures in a short

timescale. Therefore, an extension of the regulatory timescale for implementation of such capital-heavy requirements is strongly recommended, coupled with a low-cost capital funding facility, to reflect the precarious financial position of regional airports and their inability to fund such heavy one-off expenditures.

WHAT DO WE NEED OVER THE NEXT 2-3 YEARS?

State investment, or state-guaranteed investment in air cargo hub facilities should be considered as a significant opportunity to grow Ireland’s aviation industry and support the regional economy.

Government should look at measures, temporary or permanent, to boost take- home pay for aviation workers in the cargo sector. This could be by way of special personal tax reductions or a form of additional income. This improvement in take-home pay for staff with no additional cost to airlines, would support Irish cargo airlines by making them more competitive against global competitors (non-European) in the critical recovery years ahead.

EU leadership will be required, supported by Member States, in maintaining a level playing field in the competition arena and keeping routes and services open. Uneven government aid all over Europe has initiated a shift in market powers where European regional carriers will suffer and will face closure. There are 5 regional airlines in Ireland; ASL Airlines Ireland, CityJet, Stobart Air, Hibernian Airlines and SAS Ireland. The demise of regional airlines will have a direct and brutal impact on the economic recovery of the European regions and the people living there, working directly in the industry or dependent on infrastructure. The risk of airline bankruptcies remains very high throughout the coming months and possibly years, leading to lost connections and a reduction in consumer choice. All measures both at EU and national level should be aimed at mitigating costs and protecting revenues and routes. Any future EC guidelines or recommendations should avoid placing additional burden on airlines, unlike the unfortunate recommendation on vouchers.

Aviation needs the introduction of a digital single sky through an efficient and integrated air traffic management system by updating and adapting the existing regulation to the crisis, as well as to future requirements.

The aviation industry needs an EU261 reform. Negotiations within the Council put on hold because of the crisis will hopefully resume under the German presidency, including the consideration given to safety issues and a permanent provision on refundable vouchers in case of cancellations as a result of serious pandemics or a global crisis. Ireland should push for EU support for a more environmentally sustainable air transport sector through scaled-up investment programmes.

Funds are necessary for a green recovery in the following areas: Clean Sky and Clean Aviation programme (to develop the next generation of technologies for cleaner aircraft and engines); SESAR to enhance the benefits of SES; increase production and uptake of SAF (through R&D support and adequate legislation); availability of EIB lending facilities for investments in new aircraft; and clarity on CORSIA’s baseline as soon as a matter of immediate concern.

Andrew Kelly ASL Aviation Holdings 16th June 2020

Written Submission to the Taskforce for Aviation Recovery

As a team of global experts in biosecurity whose technologies are already implemented in a number of airports around the world, Biosecurity Systems Ltd is pleased to contribute to the Irish Government’s Aviation Task Force Report.

Our recommendations are designed to give airline staff and visitors to and from Ireland greater confidence to travel. Otherwise, billions of Euro in revenue is likely to be lost and thousands of jobs in the airline, tourism and allied sectors could disappear. Giving Ireland the competitive advantage of being able to market itself as a biosecure destination internationally would help protect these jobs and livelihoods.

Introduction

Biosecurity Systems delivers integrated technology and services to diminish the risk of COVID- 19 and other epidemic infections in the workplace. We are an international group of technologists, health experts and security experts who implement global best practices in technologies, threat intelligence, disinfection and screening operations. Our aim is to ensure that visitors, proprietors and staff are safe and confident.

Biosecurity Systems provides complete analysis, design, supply and management of a unique solution of technologies, processes and software for organization’s facilities and services, including preventative maintenance. The company, and its sister company Voy Robotics, is also a leading producer of robots which can deploy UV pulsating lights or spray disinfectants. Voy Robotics also manufactures autonomous delivery robots.

We are pleased to contribute to the Irish Governments Aviation Task Force Report.

Dr Paul Twomey who is the main contributor to this submission and CEO of Biosecurity Systems Ltd is the former CEO of ICANN, the global coordination body for the Internet. Paul is also an advisor on Artificial Intelligence to the G20. He has served on the board of the Atlantic Council and chaired the Task Force on the Future of the Internet for the World Economic Forum.

Dr Catherine Hallahan, the Chief Medical Operations Officer is a native of Ballina in Co Mayo, is one of the global Irish and is a highly successful medical entrepreneur. The Advisory Board of

Biosecurity Inc includes experts from the fields of national COVID-19 health administration, infection control, epidemiology, biosecurity and former senior international politicians.

The new normal: the aviation sector will have to counter the next pandemic, not just COVID-19

Recent epidemiological history teaches us two stark lessons: • The globalization of the world’s socio-economy, driven in part by affordable and expanding air and marine transport, means that disease outbreaks are more likely to become epidemics and epidemics are more likely to become pandemics; and • Growing human population and density are bringing more human-wildlife interaction, one result of which is additional opportunities for pathogen transmission.

COVID-19 is not a one-off event.

Such examples of recent pathogen transmission include HIV, Bird Flu, SARS, MERS, Ebola, Hendra and Zika. Other recent outbreaks include bovine tuberculosis, rabies and leptospirosis.

Gavi, the international vaccination alliance, has nominated 10 lethal diseases for which we do not yet have vaccines each of which could be the next pandemic.1

Further, the necessary social and economic lock down to combat new diseases like COVID-19 also means that resources are being denied to the established processes to control known global killer diseases. To diminish the risk of community transmission of COVID-19, the World Health Organization has recommended that all preventative mass vaccination campaigns be postponed.2 Twenty-three countries have already suspended their measles program and nearly as many are considering to do so. Eighteen of these countries have reported a measles outbreak. Over 14 million people in the last several months have already missed out on vaccinations for polio, measles, yellow fever, cholera and meningitis. Consequently, over 6,500 children have died from a measles outbreak in the Democratic Republic of the Congo alone. Diphtheria is appearing in South Asia.3 Europeans countries like Ireland are going to have to prepare for increased numbers of these diseases entering their communities over the next several years.

1 See https://www.gavi.org/vaccineswork/10-infectious-diseases-could-be-next-pandemic 2 See https://www.sciencemag.org/news/2020/04/polio-measles-other-diseases-set-surge-covid-19-forces-suspension- vaccination-campaigns 3 https://www.nytimes.com/2020/06/14/health/coronavirus-vaccines-measles.amp.html

Just as the September 11 attacks illuminated an existing terrorist threat and transformed airport security worldwide, COVID-19 will change the importance of biosecurity measures in air transport for the next decades. COVID-19 is a searing experience for travelers and they will be looking for the aviation sector and governments to be prepared to stop the next epidemic from becoming a pandemic.

Recommendation: Don’t just invest for post COVID-19 reopening - prepare for the next infection threats.

More than the recent lock down, passengers’ fear of travel and airports threatens the Irish tourism and business economies for years to come.

Potential travelers remain very nervous about flying. The International Air Transport Association (IATA) has determined that in June 83% of regular passengers were concerned about catching COVID-19.

But the challenge for the Irish economy is that this fear will have severe implications beyond the control of the virus.

IATA has commissioned a multi-period survey of recent tourist and business travelers to find out about the impact of COVID-19 on expected traveling behaviours.4 The study explores perceptions of 4,700 panel members from eleven countries (Australia, Canada, Chile, France, Germany, India, Japan, Singapore, UAE, UK and USA) who traveled in the last 9 months. Although there is variation among the nationalities it is not significant for our analysis here. As many of the nationalities make up the mix of visitors to Ireland, the survey is applicable to Irelands future travel trends.

The survey shows that a large proportion of travelers will postpone travel even when they consider the virus is under control. As Exhibit One shows, even after the pandemic passes, 2.1 million passengers will not travel to Irish airports/ports for at least a year and another 4 million will not travel for at least 6 months. These numbers have grown by about 50% since April.

4 IATA, Passenger Insights in the time of Pandemic, reports 1 (April 2020) and 2 (June 2020).

Exhibit One

Once an organization or someone you trust has confirmed the coronavirus/COVID-19 is no longer a threat, how long would you wait, if at

all, to return to your usual travel plans? Size of this segment in number of Inbound passengers to Irish JUNE 2020 APRIL 2020 Airports/Ports* (June) * Based on 2018 figures Not travel for the 5 % foreseeable future 4% 0.55 m

Wait a year or so 14 % 8% 1.53 m Wait six months or % 3.94 m so 36 28%

Wait a month or two 33 % 47% 3.61 m

Not wait at all 12 % 14% 1.31 m

Source: https://www.failteireland.ie/FailteIreland/media/WebsiteStructure/Documents/3_Research_Insights/Key- Tourism-Facts-2018.pdf?ext=.pdf; IATA, Passenger Insights in the time of Pandemic, reports 1 (April 2020) and 2 (June 2020).

The economic implications to Ireland are very significant. Even after the virus is brought under control (at earliest mid 2021) out of country tourism expenditure is likely to be down by €2.9 billion in the first 12 months and €1.4 billion in the second year.5

As well concerns about travel in aircraft themselves, the IATA survey shows that one of the drivers of passenger fear of traveling is conditions in airports – and that fear of airports will continue beyond the pandemic. Exhibit Two illustrates the concerns of passengers in various parts of the airport experience.

5 Based on Fáilte Ireland, Tourism Facts 2018, September 2019 https://www.failteireland.ie/FailteIreland/media/WebsiteStructure/Documents/3_Research_Insights/Key- Tourism-Facts-2018.pdf?ext=.pdf and IATA, Passenger Insights in the time of Pandemic, reports 1 (April 2020) and 2 (June 2020).

Exhibit Two

Once the pandemic has subsided and it has been declared safe to travel, if you were to take an airplane trip how concerned would you be about possibly contracting the coronavirus/COVID-19 as a result of each of the following?

While airport biosecurity is of high concern to all passengers, it is a peak concern for the passenger segment planning to postpone air travel by more than one month – the very passengers who will not spend €2.9 billion in the first 12 months after disease control. Exhibit Three shows the need to address this group’s fears about airports if Ireland is going to achieve at least some of this presently unlikely €2.9 billion in expenditure.

Exhibit Three

Recommendation: Based on our experience of dealing with this crisis internationally we believe it is vital that Ireland implement a world-leading regime of biosecurity, especially at the airports and ports. Urgent action, akin to that taken by America and the European Union in relation to Counter Terrorism post the 11th of September 2001, is required.

Ireland has an opportunity to take a leading position and promote Aviation Biosecurity as a national competitive advantage

The dynamics of international coordination of health advice in aviation involves so many different countries, airports and airlines so that it must by necessity result in a common minimum approach. Our experience in interacting with chief Medical Offices and health authorities in a range of countries has shown that most have little understanding of what new technologies such as robotics and Artificial Intelligence can offer in deploying disinfection, screening, tracing and analysis of data.

Consequently, recommendations from the various multilateral bodies have proposed a more traditional approach to airports: more cleaning, social distancing, contactless documentation, increased ventilation and passenger temperature measurement. Meanwhile, other

destinations are exceeding these standards for competitive reasons, e.g. Abu Dhabi, Dubai, Doha, Singapore, Hong Kong, Guangzhou, Tianjin, Xiamen, Edinburgh. For instance, airports in the Gulf are introducing advanced technologies to position themselves to customers as the most advanced and efficient in combatting COVID-196.

While we certainly agree that Irish airport should adopt as a minimum the Aviation Health Safety Protocols developed by the European Centre for Disease Control (ECDC) and the European Aviation Safety Agency (EASA), we would urge that Ireland pursue global best practices in airport screening, triaging and disinfection. Giving Ireland the competitive advantage of being able to market itself as a biosecure destination internationally would help protect jobs and livelihoods. Exhibit Four shows the size of the prize which is available to a country which can position itself as being more biosecure in its tourism infrastructure than other countries within the European market.

Exhibit Four A world leading biosecurity offering can help Ireland gain a competitive advantage in an initial $92 billion European airline market

Once an organization or someone you trust has confirmed the coronavirus/COVID-19 is no longer a threat, how long Number of Total Airline would you wait, if at all, to return to your usual travel plans? Passengers* revenue*

Not travel for the June 2020 5 % foreseeable future 55.8 m $10.2 B

Wait a year or so 14 % 156.4 m $28.6 B Wait six months or 36 % 402.1 m $73.4 B so

Wait a month or two 33 % 368.6 m $67.3 B

Not wait at all 12 % 134.0 m $24.5 B

* Source IATA based on 2018 figures

6 For instance https://www.magzter.com/article/Newspaper/Gulf-Today/Abu-Dhabi-Airports-To-Deploy-New- Technology-To-Counter-Covid-19

Our approach is to use best practice technologies and processes for screening, triage and disinfection to minimise the risk to workers, residents and visitors of infection from serious infectious diseases, including COVID-19, SARS and MERS, from the incoming passengers at the airport. We take travelers and workers through integrated layers of screening measures linked together by our proprietary ”whole of house” software.

These include: • A complete screening (and if chosen, testing) regime is in place which can include quarantining/turning back departing or quarantining arriving passengers. This process is overseen by nurses and medical staff that either we or the local country supply. • Biometric identity systems to eliminate the need for touching objects such as tickets, passports, identity cards etc. • Health Card Processing through Artificial Intelligence data processing and cognitive searching for identification of risky passengers • A rigorous regime of disinfection including hand sanitizing stations; high volume disinfection channels using completely nontoxic, non-corrosive and non-harmful chemicals; baggage disinfectant equipment and tunnel for checked-in luggage and luggage trolleys • Temperature screening and blood oxygen monitoring which are key in detecting danger signs in people suffering from the diseases. High volume walk-by thermal imaging. Ensure compulsory non-touch hand sanitization before directing passengers to high volume testing of blood oxygen levels coordinated though our integrated monitoring software and personnel. Visitors who display non-standard readings are isolated from other visitors and directed to immediate support by nurses we supply for testing for potential infection and handling according to national health protocols.7 • Support existing cleaning and janitorial staff with ultra-dry mist disinfection autonomous robots for populated public halls and UV pulse disinfection and plasma air filtration robots for high risk areas such as bathrooms (which needs cordoning off). Round the clock mist disinfection of populated arrival halls, luggage halls, departure hall/gates, toilets, staff quarters etc. As Hong Kong Airport has shown

7 Pulse oximeters are being used in Singapore to both monitor Covid-19 patients for clinical deterioration and to identify infected people who are not showing other symptoms. “As a result, even if they have already been infected, or they are still infectious and passing the virus to somebody else, they don’t know it,” Manpower Minister Josephine Teo said while announcing the new policy, adding that pulse oximeters can help the ministry conduct “health surveillance ... in a more comprehensive way” See more at: https://www.scmp.com/week- asia/explained/article/3083871/why-singapore-issuing-20000-pulse-oximeters-migrant-workers The Singapore MOH has said that pulse oximeters should be part of a more comprehensive clinical assessment that includes checking the patient's contact history, as well as other symptoms such as fever or cough. This is why Biosecurity Systems is linking them to temperature measurement and health card analysis and diverting positive- reading passengers to nurses for further questions and testing. Of course we have to ensure that oximeters are being used properly for accurate measurements of the degree of oxygen saturation in the blood. Low readings can also be a result of other medical conditions including asthma and heart disease – again showing the importance health card information and of nursing intervention.

seeing disinfection robots in continuous operation produces improved passenger confidence as well as improved disinfection outcomes.

The aim of the solution is to ensure that visitors and staff are safe and confident. Like existing physical security measures in airports, advanced biosecurity technology and processes are directed both to minimizing risk and to increasing the confidence of passengers to return to flying.

The costs involved in implementation of such advanced technologies and solutions are minimal compared with the economic losses that will come from the 19% of travelers who say they currently don't intend to use airports and airlines in the coming years.

Adopting world leading biosecurity solutions at Ireland’s airports (and ports) would only be part of a range of initiatives Irish authorities can take to counter the pandemic while still stimulating economic growth. But as Exhibit Five shows, if the adoption of world leading biosecurity solutions gave confidence to merely one tenth of the 19% of travelers the additional expenditure in Ireland would be €183 million.

Exhibit Five

If delivering … the total visitor revenue impact would be: Biosecurity at airports was to attract only 10% of the 2.1 million €183 million “postpone travel for 12 months or more” segment to travel

sooner… Source – https://www.failteireland.ie/FailteIreland/media/WebsiteStructure/Docum ents/3_Research_Insights/Key-Tourism-Facts-2018.pdf?ext=.pdf, IATA

Recommendation: Adopt the minimum European Union standards but go further to establish world leading solutions so as to promote biosecurity as a national competitive

advantage in the global tourism industry. To that end, amend the existing language in the draft report to include

3: Code of Practice for Safe Air Travel

Urgently adopt a national Code of Practice for Safe Air Travel, which incorporates the Aviation Health Safety Protocols developed by the European Centre for Disease Control (ECDC) and the European Aviation Safety Agency (EASA) the Irish context and also establishes world-leading advanced practices and technologies, including for airport and port biosecurity.

A code, aligning with the ECDC and EASA protocols but also mandating advanced practices and technologies needs to be urgently concluded and published. This urgent conclusion and publication of the Code of Practice should then facilitate its implementation ideally by 1 July 2020.

Who should pay?

The health and travel benefits of increased biosecurity measures most clearly accrue to travelers themselves. There is a solid history of passengers directly paying levies for stepped up security measures following terrorist events. Such a model would be reasonable in response to the global pandemic.

Economic benefits also largely flow to the tourist service companies and employees, their suppliers and consequently the public exchequer. Direct expenditure in tourism businesses by out-of-state visitors in 2018 was €7.4billion. Total employment in the sector (including domestic tourism) was approximately 260,000 with a significant regional distributive effect. Total tax revenue from the sector was €2.2billion, accounting for 4.0% of all tax revenue.8

It would be best not to cause unintended losses to GDP and employment by placing a full cost burden on airports or airlines to deliver biosecurity – this could result in an incentive to only undertake lowest cost and minimum necessary actions by these players – who capture only a small proportion of the total tourism pie. The result would be no distinguishing message (“visit

8 Fáilte Ireland, Tourism Facts 2018, September 2019 https://www.failteireland.ie/FailteIreland/media/WebsiteStructure/Documents/3_Research_Insights/Key- Tourism-Facts-2018.pdf?ext=.pdf

10 biosecure Ireland”) to potential inbound travelers nor increased safety to the Irish traveling public.

To capture the whole of economy externalities it would be best for a payment scheme that does not place the burden on airports or airlines but rather puts it on the travelers themselves and/or on the tax payers – or some combination of both. An example of a hybrid model could be the government providing initial funds for the establishment of world best practice services to be repaid from a very modest passenger levy which could also fund ongoing operations.

As an illustration, our experience of negotiations with governments has ranged from a full governmental payment for set up and annual operational fees through to a model with no up- front cost and a sustainable long-term passenger levy model.

Conclusion

Biosecurity at airports and on airlines is now firmly in the public eye and key to the future survival of much of the global travel industry. Ireland can take a lead in Europe and in doing so protect a vital part of its economy by embracing the processes outlined in this submission.

17th June 2020

Submission to

Aviation Recovery

Taskforce

Document Classification: Class 1 - General 1. INTRODUCTION

The impact of the Covid-19 crisis on the aviation industry has been catastrophic. The global pandemic has led to the collapse of traffic at Ireland’s two largest gateways - Dublin and Cork airports. Passenger numbers fell by 99% in April and May and while the two airports had enjoyed a positive start to the year in terms of traffic growth, the impact of recent months means that overall 2020 passenger numbers have already declined by 55%.

As a result, daa is on a trajectory to incur very significant financial losses this year, and has had to undertake a range of cost cutting actions in order to maintain its future financial viability – including the introduction of reduced pay for employees, and the implementation of measures to significantly reduce employee numbers across our businesses.

Looking to the future, it is clear that our industry will continue to face unprecedented challenges for an extended period. For 2020, latest projections indicate that passenger numbers at Dublin Airport are likely to be less than 9 million (>73% decline on 2019). In 2021, traffic could potentially be reduced to 21 million passengers at Dublin and Cork airports, which is an optimistic forecast and represents a reduction of almost 40% in traffic versus 2019 levels.

The impact of this for Ireland’s economic health cannot be understated – as a small, open economy, Ireland is critically dependent on its air links to facilitate economic activity and to drive business growth and development. An Intervistas report completed in 2019 showed that direct employment at Dublin Airport totals 21,500 jobs, while the airport facilitates another 108,200 jobs nationwide, generating €9.8 billion in Gross Value Added (GVA). Cork Airport generated €904 million for the South of Ireland economy and contributed to the employment of 12,180 people. Further, 75% of Ireland’s tourism economy is based on international tourism.

As a nation, our path to economic recovery will be underpinned by the extent to which we can protect our air connectivity during this crisis and ensure its recovery and restoration over time. daa therefore welcomes the establishment of the Aviation Recovery Taskforce and the opportunity to participate as a member. It is essential that swift action is taken by Government and all key stakeholders, to address the issues facing our sector.

Outlined below are our recommendations for actions that need to be undertaken both in the immediate term, to mitigate against any further impacts on the aviation sector, and also in the medium to longer term, to protect the future capability of the industry and to ensure sustainable connectivity to Ireland is enabled once more.

Immediate Recommendations Further Recommendations 1. Replace current self-isolation restrictions Review airports charges regulation 2. Reduce social distancing requirements Continue to prioritise investment in airports 3. Build confidence to fly Amend North Runway operating conditions 4. Government supports, including Implement Brexit contingency measures • Extension of Temporary Wage Subsidy Scheme • Fund to assist in rebuilding route networks • Capex for safety and security projects • Waiver for rates and state agency charges 5. Support commercial revenue generation at airports

June 17, 2020 2

Document Classification: Class 1 - General 2. RECOMMENDATIONS FOR IMMEDIATE ACTION

a) Replace Current Self-Isolation Restrictions Ensuring appropriate public health protection must remain at the core of Ireland’s approach throughout this pandemic. However, it is also important that – in responding to this crisis – Ireland seeks to ensure that the measures it takes effectively and appropriately balance economic considerations, and do not create barriers to Ireland’s economic recovery. Ireland is currently lagging behind many of its European counterparts with regard to relaxing self- isolation restrictions for EU countries – 13 EU member states have either lifted quarantine / self- isolation restrictions or implemented limited measures. It is therefore daa’s recommendation that a review of the current self-isolation regime be undertaken and the protocols in relation to border control and travel restrictions be relaxed. Alternative measures have been identified and could be adopted as soon as possible: • Replace the current 14-day self-isolation instrument with a more targeted track and trace system for arrivals and agree and open up ‘travel corridors’ with similarly affected countries with similar public health capacity.

• The European Commission has strongly encouraged remaining Member States to finalise the process of lifting the internal border controls and restrictions to free movement within the EU by 15 June 2020. Therefore, these changes should be urgently implemented, well in advance of the date set for finalising the recommendations of this committee i.e. 10th July and be communicated as part of the Government’s plan for re-opening the economy. • The gradual and coordinated phasing out of the travel restrictions to third countries from 30 June should be supported, in line with European Commission recommendations.

b) Reduce Social Distancing Requirements Strong consideration should be given to reducing social distancing rules applied to the aviation sector from 2 metres to 1 metre. Such a change would be in line with World Health Organisation (WHO) requirements and could be mandated for the aviation sector given the range of strict measures being implemented in our industry e.g. access to airport buildings restricted to those travelling, enhanced sanitisation measures and recommendation to wear face coverings throughout the passenger journey.

The continued implementation of 2 metre social distancing rules is creating very significant challenges for our sector and will become more challenging as society continues to reopen over the coming weeks and months given the constrained footprint in which we operate. In fact, it is estimated that between 60% and 75% of total airport capacity will be lost due to the implementation of social distancing measures, particularly at key areas such as check-in, security and boarding gates. The impact will be the creation of extended and complex queuing arrangements that is likely to stretch beyond the internal footprint of the terminal building, particularly as numbers flying start to increase. In order to deal with the capacity challenges that will inevitably arise, daa may need to consider local slot co-ordination rules to potentially restrict terminal capacity for the remainder of the year.

Alignment with the World Health Organisation (WHO) guidance which advises people to keep ‘a distance of 1 metre (3 feet) between yourself and anyone who is coughing or sneezing’ would allow aviation to begin to operate in a more sustainable manner, as Ireland’s economy recovers.

June 17, 2020 3

Document Classification: Class 1 - General c) Build Confidence To Fly As we move forward, passenger safety and protection will remain a core and shared priority for the aviation sector.

For daa’s part, it is currently implementing a series of public health measures to protect and enhance the health and safety of passengers and staff as a result of COVID-19. The measures reflect Ireland’s national COVID-19 guidelines and also best practice in the European aviation sector, as set out in the recent guidelines devised by the European Aviation Safety Agency (EASA) and European Centre for Disease Prevention and Control (ECDC).

Measures include recommended wearing of face masks/ face coverings, limited entry to terminal buildings and enhanced cleaning processes. Almost 1,000 hand sanitiser units have been installed at Dublin and Cork airports, 760 protective plexiglass screens are in place at close contact points between staff and more than 10,000 new signs are in place to advise on social distancing, hand hygiene and other measures.

However, to further enhance these measures and build public confidence in flying, further initiatives should be supported and undertaken including:

• Encouraging initiatives such as mobile or home-printed boarding passes, electronic or home-printed bag-tags and personal data capture online to minimise passengers’ use of touchpoints, as well as time spent in potentially congested areas. • Committing to timely and aligned communications to passengers from Government and industry to avoid confusion and clarify expectations in respect of issues such as travel advisories, face masks, locator forms, public transport etc.

• Ensuring availability of sufficient public servants (e.g. in immigration and customs) to support ramp up of airport operations and implementation of additional measures necessary to protect passengers and staff.

• Engaging with industry before any further measures are considered prior to their introduction e.g. additional sanitary measures EASA has concluded that temperature/thermal screening is not effective or efficient in detecting Covid-19. If it is considered that Covid-19 testing regimes (whether full medical testing, thermal testing or any other type of testing) could form part of the Irish response to the pandemic, it is critical that this is underpinned by a robust process with a statutory basis, that sufficient provisions and funding are made available for implementation by Government, and that all testing is carried out by the appropriate public health authorities/a suitably qualified third party. Close regard should also be given to the practical implications of any potential Covid-19 medical testing for passengers (given requirements for long waits, and passenger segregation), as well as its feasibility when applied to large passenger volumes (given requirements with respect to testing capacity, resourcing, availability of suitable testing areas, availability of segregation/waiting areas for large numbers of arriving passengers etc.).

d) Provide A Range of Government Supports Airports have been profoundly affected by the Covid-19 crisis and uncertainty remains around the recovery trajectory. Swift measures are required to protect the sector and stabilise jobs, thereby assist in Ireland’s overall economic recovery. daa remains in an immensely challenging financial position. The European Commission is providing flexibility in the application of State

June 17, 2020 4

Document Classification: Class 1 - General aid rules and is willing to accept that airports in the current circumstances operate in the ‘public remit’ if, like the daa airports, they must remain open. This means that operations can be financed by governments outside the state aid rules. To stem the tide of financial loss there are a number of supports which could be provided by Government in support of our airports: • Maintain the Temporary Wage Subsidy Scheme (TWSS) for our sector for an extended period (i.e. beyond 10th Aug)

• Create a substantive fund to assist our airports to rebuild their route networks and restore connectivity for the benefit of the wider economy. Further engagement is required to determine best means of disbursement.

• Ensure a waiver of local authority rates and reduce / eliminate payments to other State Agencies e.g. CAR levies, IAA security charges • Fund the implementation of additional measures that are required due to the pandemic e.g. sanitisation measures and PPE

• Recognise daa as a company eligible for postponement/deferral of revenue debt (PAYE and VAT)

• Commit to supporting capital expenditure for essential safety and security projects at Cork and Dublin Airports. It is important to appreciate that airports and airlines are currently facing equally severe impacts as a result of this crisis. Accordingly, any measures adopted at this time must not benefit one player in the aviation sector at the expense of another – as would be the case for example, if airports were required to further lower or forego the payment by airlines of airport charges. daa’s airport charges are already amongst the lowest in Europe, and below cost for the new levels of activity, with a 22% reduction imposed at Dublin from 2020 on 2019 as part of the recent price review carried out by the Commission for Aviation Regulation. Ultimately, we need to ensure that initiatives taken to address the current crisis do not undermine the fundamentals of a self-sustaining industry model as this could be much more difficult to repair later. daa recently undertook research to identify the top factors that would influence people to recommence flying - key issues were the safety of destination, health protection en route, travel restrictions etc. This highlights the need to implement measures to support all stakeholders in addressing the concerns highlighted by potential passengers such as:

• funding for the additional measures that all parties need to implement due to the pandemic e.g. PPE, sanitisation materials; and

• the allocation of sufficient marketing funds to re-establish the Irish tourism brand in the marketplace. We also support the instigation of a stimulus package for the tourism and hospitality sectors, aligned with recommendations from the Tourism Recovery Taskforce, and the Irish Tourism Industry Confederation’s (ITIC) calls for the establishment of a dedicated Department of Tourism. Finally, implementing any additional taxes on aviation at this juncture would have a further dampening effect on consumer demand for businesses trying to recover from this crisis and could result in capacity cuts. In this context the Taskforce should recommend against any such introduction.

June 17, 2020 5

Document Classification: Class 1 - General 3. FURTHER RECOMMENDATIONS

a) Review Airport Charges Regulation at Dublin Airport An urgent review of airport charges regulation in Ireland is clearly necessary. The current system which applies at Dublin Airport illustrates how a faulty regime can compound the impact of a profound shock and puts the financial viability of key State strategic infrastructure at risk. As investment and regulatory regimes are inextricably linked, changes are urgently required to ensure the State’s aviation policy is enabled through a coherent approach to the regulation of airport charges. In the context of a response to the Covid crisis, there are a number of immediate measures that can be taken:

• The current service quality regime is now irrelevant/impractical and needs complete review - penalties should be suspended until new measures are agreed.

• The regulatory expectation for continuously achieving operating efficiency significantly reduced Dublin Airport’s cost allowances in the current regulatory period (2020 – 2024) and left no contingency for unanticipated costs such as those related to Covid-19. To the extent that direct state support is not provided to fund these measures, then we require the requisite regulatory approvals and certainty on the recovery of these costs which could be substantial and are currently unfunded as a result of the rigid regulatory framework currently in place.

b) Continue to Prioritise Investment in Airport Infrastructure Prioritising the development of key infrastructure, particularly airport capital investment that facilitates connecting Ireland to the rest of the world, must be a key element of the Government’s national economic stimulus plans. • Accelerate capital allowances on airport investment for a 5-year period to encourage and support investment in long term airport infrastructure to support a resurgence in the economy and travel industry.

• Explore funding opportunities through the Pandemic Stabilisation and Recovery Fund (€2bn subset of ISIF) to support the development of airport infrastructure

• Prioritise policy and legislative changes to speed up the planning process • Ensure that airport facilities required to address Covid (e.g. marquees or other temporary facilities) are given exemption status by the Department of Housing Planning and Local Government for planning purposes

• Renew the commitment to addressing access issues at daa airports as part of Government’s infrastructure development plans (Project Ireland 2040) – roads, Metrolink etc.

c) Amend North Runway Operating Conditions Dublin Airport’s North Runway is a key piece of strategic infrastructure for the Irish economy, particularly in the post-Covid era we are now entering. It will facilitate the growth of inbound tourism, provide greater access to overseas markets and act as a catalyst for Foreign Direct Investment. Although construction of the runway is progressing well, two planning conditions attached to its delivery threaten to undermine the benefits it can bring, by restricting aircraft movements across the entire airfield to 65 between the hours of 11pm and 7am and prohibiting use of the new runway during the same timeframe. Pre-Covid, Dublin Airport was operating in excess of 100 flights during that period.

June 17, 2020 6

Document Classification: Class 1 - General Support for the removal of the restrictive operating conditions should be prioritised to protect the long-term operational capacity of Dublin Airport and ensure that capacity constraints are not experienced as growth returns.

d) Implement Brexit Contingency Measures Indications are that Brexit negotiations are slow and protracted and concerns around a no- deal Brexit are rising. Given the devastating impact that Covid 19 has already had on the aviation industry and the jobs and economic value it generates, it would be difficult to withstand the further significant blow that a no deal Brexit would represent at a time when the industry would be hoping to see the return of traffic.

It is therefore crucial that there is active engagement with the EU/UK to put arrangements in place to maintain air services in the event of a no-deal Brexit e.g. via a separate negotiated air transport agreement or by the implementation of contingency measures to ensure basic connectivity is maintained.

e) Support Commercial Revenue Generation at Airports Rebuilding non aeronautical revenues will be a significant challenge due to social distancing measures, and also because of reduced spending power on the part of those travelling. Stimulating these revenues helps to maintain competitive aeronautical charges and could be assisted in the following ways:

• Support from Government agencies for new ways of fulfilling sales e.g. by means of home delivery

• Ensuring that airport shopping is excluded from any restrictive on-board allowances • Supporting an upcoming request to change EU legislation to facilitate the introduction of Arrivals Shopping from Duty Free destinations into European airports. Outside of the EU, practically all major airports in Asia, the Middle East, Australasia, the EEA and Eastern Europe have duty-free on arrival. Its introduction in Europe would level the playing field and address the likely impact of such an introduction in the UK post Brexit.

4. CONCLUDING REMARKS

The recommendations proposed in this document are varied and wide ranging but are necessary to start Ireland on the path to recovery. Whilst decisions relating to Government support will be difficult given the constrained financial position that Ireland will experience over the coming months and years ahead, any and all decisions must be assessed in terms of long- term viability and return on investment. It is crucial that state supports do not result in market distortion or an uneven playing field.

The aviation sector was central to Ireland’s recovery in the aftermath of the global financial crisis of 2008 by facilitating new Foreign Direct Investment and driving record tourism growth. Given the right support, the sector will once again play a similarly critical role in the aftermath of this crisis.

June 17, 2020 7

Document Classification: Class 1 - General

DCU CENTRE OF EXCELLENCE FOR DIVERSITY AND INCLUSION Submission to the Taskforce for Aviation Recovery 16 June 2020

THE AVIATION INDUSTRY NEEDS TO BE REFLECTIVE OF THE COMMUNITIES & PEOPLE IT SERVES.

In terms of diversity the three main areas of concern within the aviation sector are: 1) limited numbers of people with lower socio-economic status, 2) gender balance and representation of females within the workplace, 3) few people with different ethnicity.

There is now an opportunity to take real action and ensure that when the industry recovers it is a more diverse and inclusive industry than what it was. This submission outlines four key areas for consideration.

Note: We recommend ‘diversity’ is given a dedicated section (or at least called out individually) within the Summary Information Paper under the ‘Suggested Recovery Issues’ or within any future plan. For example: f) Diversity and Inclusion for a Sustainable Sector

To create a more sustainable sector, reflective of the customers and communities that it serves, it is now imperative that the industry, supported by Government, does everything they can to ensure it becomes more diverse and inclusive. In line with Sustainable Development Goals (i.e. 5, 8, 10) the sector needs to chart a more equal route to recovery.

Measures to support employment sustainability and diversity monitoring within the industry are important to address legacy structural issues in the sector.

Q1 – What is required to assist employment sustainability, diversity and balanced development? Q2 – Are there specific measures available, as demand recovers, which can help accelerate job creation in the sector? Q3 – Is there an opportunity to address legacy structural issues in the sector around gender balance in employment and career opportunities and employee diversity levels?

*************************************************

There are four key recommendations that should be included in a plan for recovery.

1. EMPLOYMENT SUSTAINABLITY – TALENT RETENTION

Now, more than ever, the aviation sector needs to hold onto its talent. Many jobs have been lost but it is those that are left behind that will have the difficult task of getting things moving again. We cannot do anything about redundancies but employers and government can ensure support, guidance and policies around working practices within the sector. People need to be considered, backed and supported. Below are the top three priorities for employers right now.

a) FLEXIBLE WORK PRACTICES: There should be as much support as possible for employees around flexible and remote working so the industry does not lose more valuable talent. In addition to working in an industry that has been temporarily decimated and is plagued with uncertainty, many are also balancing caring duties at home. People are likely physically and mentally exhausted and may also have lost colleagues through voluntary or forced redundancy. Many may be considering other options for the future, as they are uncertain about what lies ahead. It is important that employers actively encourage flexible, inclusive working arrangements, leading from the top, to encourage people to stay. Action:  SHORT TERM – Government supported policies / practices should be shared as soon as possible.

b) CAREER DEVELOPMENT AND TRAINING: Employers need to send a clear message to their employees. We value you, we need you and we want to keep you. Retaining strong talent will help the industry to recover more quickly, leading to accelerated job creation. For employees who have lost colleagues through redundancy, employers need to ensure they stay engaged and motivated. They will need training to provide them with the skills required to confront the difficult tasks ahead and deal with any current issues. They also need to know they are valued, with career development pathways and plans for progression. This will prevent them from moving on or disengaging. Clear communications are needed to let the industry know its people are supported and are vital to recovery and this should be backed by government messaging. Action:  SHORT TERM – Intention for provision of Government supported development programmes in areas such as leadership and management development, high potential development training. Employers should provide training in areas such as resilience and managing people remotely.  MEDIUM TERM – Implementation of leadership and management development, high potential development training programmes (support these programmes through Higher Education)

c) GOVERNMENT SUPPORTING POLICY AND PRACTICE: Across every industry there are organisations that are at different stages of their diversity and inclusion journey. They are likely more equipped with proactive policies and practices than others. These more diverse organisations will have a better chance at faster, stronger recovery as they tap into better innovation and creativity. Now is the time to level the playing field. Government should ensure that the aviation industry has access to policy and practices on the above areas.

2. DIVERSITY MONITORING

With so much flux across the industry, it is important to support employment sustainability. To do this employers need to know who has left, who remains and who is now missing from their employee bodies. This will enable the industry to reconstruct and rebuild a more diverse sector when they are in a position to do so. The information can be used to build a sustainable people plan for the future to ensure that the industry remains relevant and innovative and continues to keep focused on the value of diversity.

a) DEPARTING EMPLOYEES: Track who is departing now to identify if they are losing more of one group than another. If possible, uncover what are the reasons behind this. If we know who is leaving, it will inform hiring in the future. This will accelerate diversity planning for the future. Action: Short term: Industry should track who is leaving. Government should promote the importance of diversity monitoring where organisations are losing large groups of people.

b) EXPERT/ACADEMIC NETWORKS: Continue to support the work being done in higher education institutions and with experts in the industry. For instance the DCU and Aviation Industry Year of Inclusion initiative is focused on conducting industry wide research to benchmark diversity within the aviation industry. The newly formed UK/Ireland academic network Covid-19 Inclusive Recovery in Aviation and Aerospace: an equality, diversity and inclusivity network (CIRAA), aims, among other things, to establish how some groups are disproportionately affected by the effects of Covid-19; and make a compelling case for a more equal route to recovery, especially in relation to the working conditions of underrepresented groups. Action: Short, medium and longer term: Continue to support the industry wide initiatives that are in place and tap into the extensive pool of academic and expert knowledge.

c) UNDERREPRESENTED GROUPS THAT HAVE LOST JOBS: Support minorities who have been made redundant to re-train/re-skill to get back into other parts of industry (i.e. women, ethnic minorities, and people from lower socio economic backgrounds). This can be done in many ways but consider scholarships to education at different levels. Action:  Short term: Assess, through diversity monitoring, who has departed and identify who to support.  Medium term: Provide scholarships/grants to education in aviation. Many courses and pathways available. Irish Aviation Students Association lists them all comprehensively here  Long term: Internships, introductions, networking into roles and jobs across the industry.

d) THE FUTURE – TARGET UNDERREPRESENTED GROUPS: The industry is currently not very diverse. To promote and encourage diverse to consider aviation, young people in secondary schools should be targeted with campaigns to promote the different pathways into the industry. Role models within the industry should be considered via a social and digital media campaign. Action: Long-term: When appropriate, a targeted campaign should be considered to reach out to more diverse, underrepresented groups.

3. LOWER SOCIO ECONOMIC INCLUSION

There needs to be equitable access to opportunities in the sector for lower socio-economic communities. This is something that needs to be addressed, backed and supported by Government. To get people to consider a career in aviation sector, there needs to be a focus placed on promotion of education and role models that can be used as ambassadors.

Actions: Medium to Long term:

 Targeted and supported pathways into existing higher education programmes  Targeted and supported pathways into apprenticeship programmes  Leverage industry role models to support the above.

4. SUSTAINABLE DEVELOPMENT GOALS

Employers are more likely to keep inclusion and diversity on the agenda if it is linked to sustainable development which is something they recognise. To address legacy structural issues in the sector, our recommendation is to align this element of the recovery plan to the following Sustainable Development Goals (SDGs) related to sustainable business and diversity and inclusion practices:

 #5 Gender Equality  #8 Good Jobs and Economic Growth  #10 Reduced Inequalities.

As the aviation industry starts to recover, it is an opportunity for the industry to reconstruct the industry in a more diverse and inclusive way - activating the innovation that is available. The SDGs provide a powerful framework to help businesses identify the positive and negative impacts of activities on immediate stakeholders and wider society. That also makes them a framework for companies to better anticipate risks, consumer demand and resource needs. They help to attract and retain staff, enable the promotion of unique propositions and strengthen supply chains.

Actions:

 Short, medium, long term – Gain insights on gender balance, race and ethnicity, representation, socio-economic and equitable access to opportunities the industry  Long term - The government monitors SDGs but they don’t monitor the people side. We recommend that the government leads by example and starts including and promoting these

SDGs and actions, policies, practices in this space in upcoming aviation division reports and collateral.

CONCLUSION

The recommendations included in this submission will enable the sector to become more diverse, more inclusive and more fit-for-the future. The aviation industry will:

 Reflect the people and communities it serves  Create working environments that value and embrace difference  Become more inclusive by supporting people at all stages of their lives  Activate diversity and therefore increase levels of innovation and creativity  Retain talent and enhance motivation within the industry  Understand the diversity, or lack thereof, of its people and create action plans to change this.

In rebuilding, the aviation industry can ensure that it is a more diverse and inclusive industry than what it was – and most importantly, that it reflects the communities and people that it serves.

CONTACTS

Sandra Healy Director, DCU Centre of Excellence for Diversity and Inclusion T: 086 264 9480 E: [email protected] www.linkedin.com/in/sandra-healy/

Pippa Halley, Research and Project Lead, DCU Centre of Excellence for Diversity and Inclusion T: 087 057 6844 E: [email protected] www.linkedin.com/in/pippa-halley-3096012b/ Submission to the Task Force for Aviation Recovery from dnata Catering Ireland Ltd.

Dear Mr. Towey

We are writing to you to communicate the impact of COVID-19 on our airline catering business and the broader importance of air services to any government and industry joint aviation transport taskforce. As one of the world’s largest air services providers, dnata requests consideration in the recently announced Task Force for Aviation Recovery for the following reasons. dnata is a global leader in airline catering, ground handling, cargo and hospitality services, globally. Prior to COVID, we employed 45,000 people working across more than 126 airport locations in 35 countries. We support more than 320 airlines every day in roles that are crucial to their ability to fly. With the near cessation of all international travel, air service industries have been severely impacted.

In Ireland we employ more than 60 workers, plus agency staff. We have recently invested in two new facilities and were awarded contracts to cater all Aer Lingus flights to Dublin, Cork, Shannon and Bel fast. It is expected that we will employ more than 200 employees whenever normal aviation business returns.

Regrettably, our operations have been significantly impacted as a result of the downturn in international and domestic travel in our country. These impacts continue to be felt and have resulted in widespread furlough activity, redundancies and temporary closure of operations across the world.

When assessing the challenges and the future of the aviation sector in Ireland, Government and industry-led taskforces cannot afford to look at airlines in isolation without considering the partners who are critical to keeping them in the air.

Airlines will acknowledge the critical role we play in their success, This is a highly interconnected industry, with high dependency on service providers.

Our industry operates on a low-margin model. We are generally paid on a per-flight or per-passenger basis, so where flights are grounded and/or passenger volumes low, our provision is cancelled and our revenue is cut off. Our main overheads are our labour force. That labour force is also undoubtedly our most valuable asset and it is crucial we protect them through this crisis. On average, it takes 1-3 months to hire, train, and security- clear new staff. Retaining our existing workforce is crucial to any rapid recovery.

Airline caterers are not represented by the main airline operator’s industry associations. We have therefore not been included in any dialogue with the aviation sector held so far. Without our voice in aviation discussions, regardless of the support to airlines and airports, the industry will suffer.

For and on behalf of dnata Catering Ireland Ltd

John Earnshaw General Manager for Ireland dnata Catering Ireland Ltd. Hawk House Cedar Drive Dublin Airports Logistics Park Co. Dublin K67 YW68

Donegal Airport

Submission to Aviation Recovery Taskforce

Air Navigation Services Division, Department of Transport, Tourism and Sport

16 th June 2020

Donegal airport like all of the National and Regional airports has suffered a sudden and unprecedented sharp decline in passenger numbers and decimated revenue due to the impact of Covid19 and welcomes the Minister’s initiative to appoint this group of highly qualified and experienced key personnel as an Aviation Recovery Taskforce to seek to get the industry back on track for a full recovery.

Short term actions needed –

*Restore Public confidence in safe air travel; In recent weeks under the auspices of the National Air Transport Facilitation Committee a number of meetings were held concerning the coordination for implementing EASA/ECDC Aviation Health Safety Protocol. The draft code of practice on operational guidelines for the management of airline passengers from arrival at the airport, through their flight and to arrival at their destination was issued last week and is now subject to agreement by the Irish Public Health Authorities – it is imperative that this document is agreed and issued without delay to enable airlines and airports to publish procedures required and promote safety measures being implemented in relation to Covid19 pandemic. *Continuation of the Temporary Wage Subsidy Scheme; The decision to extend the TWSS to the end of August is welcome. This scheme enabled Donegal Airport to maintain core staff and continue to provide its essential Dublin (PSO) route, albeit at a reduced level during the lockdown while its other key route to Glasgow, UK was suspended. The re-introduction of the full PSO service from the 2 nd June has emphasised the true value of this essential air service as people begin to return to work in Dublin and beyond and health appointments are being restored in addition to the Covid19 hospital services. *14 Day Quarantine restriction of international passengers; Donegal airport supports the withdrawal of this restriction particularly in relation to Scotland and the UK in general. There is an anomaly in imposing this restriction on passengers arriving by flight compared to those arriving in Northern Ireland by ferry – with their destination in Donegal and other parts of Ireland where no restrictions apply to people driving across the border. While the 14 day quarantine remains for international passengers it will be impossible to restore air travel. The tourism industry and businesses in general depend on quick and easy access to be restored as an immediate measure to reduce the longer and deeper detrimental impact on the economy.

Medium term actions needed – Implementation of the Regional Airports Programme - The new Regional Airports Programme 2020-2024 was due to be published following the formation of the new Government, it is now delayed further and imperative that its implementation is now expedited. The Regional Airports Programme is a highly-effective framework for supporting, enhancing and ensuring the effective operation and development of the regional airports and particularly Donegal airport as one of the remaining remote regional airports in Ireland. In the case of Donegal Airport the Programme’s effectiveness has been due to its clearly-articulated rationale and policy status, it’s clear and well-defined support schemes and strands, its distinction between economic and non-economic activities, its support for PSO services and clarity regarding the circumstances which warrant them, its alignment and compliance with EU State aid requirements, and its close, co-operative and effective management and implementation by the Department. The region served by Donegal Airport is the most remote from Dublin within the Republic of Ireland, and the airport serves a catchment and county with extremely poor land transport services, road networks and both internal and external accessibility through other transport means. The county has no motorways nor dual carriageways of any significance, no rail infrastructure or services, and no motorway or high-quality dual carriageway road access to Dublin. The Department’s previous reviews has confirmed the success and effectiveness of the Programme in respect of Donegal Airport:

 that despite earmarked road improvements set out in the National Development Plan, road transport improvements will not be realised in the short term and journey times to Dublin will remain extremely high via land transport options;

 that Donegal’s low population density relative to other regions renders its scope to develop direct routes very challenging, and its effective catchment does not overlap with those of other regional and national airports;

 while its proximity to Derry Airport is noted, Derry Airport does not currently offer a Dublin service and therefore does not compete with Donegal Airport’s main route, although it does constrain Donegal’s scope to attract new UK routes. Additionally Donegal’s proximity to the Northern Ireland border with the impending Brexit/EU agreement is expected to extend Donegal Airport’s effective catchment area within the county, while at the same time its isolation within and relative to the rest of the Republic would increase.

 the remote region of Ireland it serves, its distance from major towns in the region, and the limited public transport links that exist locally, mean there is a strong justification for a PSO service to Donegal Airport.

Donegal Airport is an important feature of the transport infrastructure serving county Donegal and provides air access and connectivity to a catchment population which faces severe geographical and land transport disadvantages. The existing Programme has ensured vital accessibility and connectivity for the region, which has contributed importantly to enterprise, tourism and community transport needs, with steady growth in passenger numbers seeing continued strengthening of the airport’s commercial performance. It is expected that the economic impact of the Covid19 pandemic will further challenge the more remote and rural weaker economies and the continued support of Government to Donegal airport’s facilities and services through the Regional Airports Programme will be even more important in the medium to longer term. Rural regions provide employment predominantly by SME’s which will be severely challenged by this pandemic and Brexit. Long term – 2/3 Years actions needed – *Route Development/Connectivity Support Donegal airport has recently undertaken detailed and systematic independent research regarding its economic impact and importance in the region it serves, to both inform future planning and to help address information gaps which were identified for all regional airports in recent reviews. While the research strands are ongoing, some of the findings are;

 amongst passengers there are high levels of attribution of the airport’s services to making trips or not, rather than simply to selecting air travel as the means of transportation; there is also continued evidence of high usage of Donegal Airport for business reasons amongst passengers

 amongst tourism operators across Donegal there is evidence of increasing importance attaching to the airport, of air access via Dublin featuring increasingly as part of the marketing and tourism business promotion, and of the airport’s existence and services increasingly featuring in the commercial business planning of tourism operators

 amongst Udarás na Gaeltachta client companies there is frequent use of the airport and air services, and that any reduction or cessation of services would have discernible negative consequences for business performance and employment, these Companies currently employ circa 3,000 people in Donegal.

 evidence of high importance amongst IDA-Ireland client companies, there is utilisation of the airport from businesses located in distant parts of the county.

 These findings, confirm both the ongoing need for the Regional Airports Programme, as well as its effectiveness in supporting connectivity and regional development in the case of Donegal. An additional fund for route development and connectivity through Dublin should be considered as an emergency measure for aviation recovery.

The recovery of the aviation industry across the world will be extremely challenging in the period ahead and as an island nation it is more important to Ireland than many other countries. Donegal is practically an island within Ireland with just over 9km of border connecting to the rest of the Republic in the south of the county. In this regard businesses across the county already had great concerns with regards to the impact of Brexit and now the severe impact of Covid19 is a further greater concern. We look forward to the outcomes from the Aviation Taskforce in supporting the challenges ahead.

Aviation Recovery Task Force 17 June 2020

Restoration of Air Travel

1. Without free movement of tourists, holidaymakers and business travellers in and out of Ireland, the future of our Airlines, Airports, Tourism and Aviation Industry is SEVERELY imperilled. This is an existential threat which appears to have been missed due to the public health emergency. 2. There was unanimous agreement at our first meeting for an immediate lifting of quarantine measures. This has not happened and remains the primary priority. 3. Ireland is now the last island nation in the EU with a greater dependence on aviation than any other country yet Government has yet to respond to the urgent and specific needs of Aviation, primarily our Airlines. 4. The EU Single Market for Air Travel and EU Prohibition of State Aid for airlines have been completely ignored, the former by Ireland (with its restriction on intra-EU arriving passengers) and the latter by Germany, France, Italy, Netherlands, Denmark and Austria. The Irish Government needs to take a leadership position regarding the EU Single Air Travel Market and EU Competition Law. 5. Aer Lingus and Ryanair have long been amongst the best exemplars as well-managed airlines with safe, reliable operations, strong growth and prudent fiscal discipline. Their strong balance sheets are now being used as a substitute for government support whilst their weaker or insolvent competitors are being financed by their governments, thereby creating an unfair competitive environment.

Financial Support for Aviation

1. Whilst TWSS has been helpful in terms of payroll support for Aviation, the duration of the scheme for the Irish Aviation Industry is uncertain. This scheme needs to run until at least the end of Winter (March 2021). 2. In order to enable Airlines to repair their severely damaged balance sheets there should be a 12-month pause on remittance of all Air Passenger Taxes, Fees and Levies at Irish Airports enabling airlines to achieve real net yield increases without impacting on consumer demand. 3. To compensate Airports for this loss of revenue the Irish Government should repay their monthly Aeronautical fee income on a per passenger basis or at least 75% of 2019 Aeronautical Income (with 25% to come from the Airport’s own restructuring/operational cost reductions). Approximate cost €300m over 12 months. 4. Ireland Inc. has a AAA+ Credit Rating and recently raised a €5Bn Euro Bond at 750bps. The Exchequer should underwrite a new €5-10bn Aviation Infrastructure Bond from which Irish based aviation business can access low cost capital to restructure and rebuild airport infrastructure, airlines fleet financing, MRO facilities and other major programmes. This will help us regain our leading position in aviation which has been undermined by almost €40bn of other EU State support for their Flag Carriers[sic].

Fórsa Submission to Task Force for Aviation Recovery

Introduction

Fórsa represents over 80,000 members across the public and civil service, state commercial and non-commercial companies and a wide range of employments in the private sector. This includes around 5,000 workers in the aviation including staff in airlines, airports and air navigation bases. The aviation sector indirectly supports in the region of 150,000 jobs across the economy including in the tourism services hospitality and aircraft maintenance and leasing. The current crisis has had a devastating impact and has put in jeopardy thousands of jobs not just in aviation, but also in the sectors that rely on air traffic services. To date the Government’s Temporary Wage Subsidy Scheme is supporting employment in the sector, and the first recommendation from the Task Force should be to keep this scheme in place for as long as it takes the sector to reach recovery. In doing so, it should recommend that employers who avail of the scheme must not make employees redundant.

Recommendation: The Task Force finds the TWSS is vital to maintaining jobs in the sector during the recovery period and should continue for as long as necessary under conditions that prevent employers availing of the scheme from making workers in the sector redundant.

Shannon Airport

Shannon airport is a major catalyst for economic development in the west of Ireland from Galway to Kerry, and underpins employment across a whole range of activities in tourism and industrial development. Thousands of industrial jobs rely on the airport for air freight and executive travel. Within the airport complex and the nearby industrial estate there are approximately 10,000 people employed.

A whole range of tourism infrastructure also relies on the airport to get their customers to their hotels. Some of Ireland’s best five-star hotels are in the Shannon region. Covid-19 has brought about new reality for Shannon airport and the dire consequences it will have for the west of Ireland unless there is urgent Government support.

Before the present Covid-19 crisis, Shannon was already in trouble as separation from the DAA has not worked. The 2.5 million passenger target to be achieved under an independent Shannon has been missed by a considerable margin and now has no hope of being achieved under the current Shannon Group structure.

In 2019, passenger numbers dropped 8% to 1.71 million. That is back to the level recorded in 2015, and is considerably lower than the 2.5 million annual passenger target set by Shannon Group Chairman Rose Hynes at the time of its independence. The 2019 passenger figures are significantly lower than the 2006 Shannon figure of 3.6 million passengers. See excel spread sheet for breakdown of Shannon passenger numbers from 2005 to 2019.

Shannon will serve considerably less than one million passengers in 2021 and the airport will take several years to get back to even 2019 levels. To put it very bluntly Shannon airport’s passenger traffic is in serious difficulty which will result in significant job losses at the airport and in the region.

Shannon is heavily reliant on transatlantic services and the Aer Lingus London Heathrow services are also critical. Year-round connections to at least two European hubs will also be critical to Shannon’s future development.

The Government must use the reality of the Covid-19 crisis to create a new beginning for Shannon airport and the region it supports. Doing nothing is not an option for the thousands of people who depend on Shannon airport for their livelihoods both directly and indirectly.

Unless urgent and decisive Government action is taken the decline of Shannon airport will not be halted and it will create irreversible economic difficulties for the entire region.

Recommendations

State Airports Economic Stimulus Plan  The Government must use the three State airports of Dublin, Cork and Shannon as part of an economic stimulus plan to help both regional and national development. State companies should be used as when first set up to create/retain employment and foster economic development. 2

Future Shannon airport structure  The Shannon Group is a property focused entity with profit as its key measurement. This is not working for the airport or the region. The Government should give serious consideration to incorporating Shannon airport into a three-airport semi-state authority under the DAA, which would ensure a coordinated focus on aviation policy and route development. For Shannon this would be a major step forward as the airport cannot compete with Dublin airport and the new authority would be in a much stronger position to develop new routes at Shannon.

Shannon-specific task force  A Shannon-specific task force should be set up to develop a new business development strategy for the airport.

Shannon route development fund  The Government should finance an emergency route development fund for Shannon. This will be required as, post-Covid-19, airlines will only develop new routes or even retain some existing routes where there is significant financial support from an airport. This will be required for a minimum of five years to ensure that routes get established and are profitable. It will be required to underpin year-round transatlantic services and European hub connectivity for Shannon.  Income from the Shannon Group property portfolio should also be used to support route development and retention. New property development should be suspended with all available cash and new borrowings by the group used to support route development.  All rules in relation to State aid must be suspended to ensure Shannon’s survival and route retention.

Transatlantic services  At a minimum Shannon needs to have year-round transatlantic services to three US hubs such as Boston, New York and a US airline hub. Year-round transatlantic services from a US carrier into one of their hubs will be vital for onward connections.  With the advent of ‘Open Skies’ in 2007, Shannon has lost an estimated 400,000 terminal passengers. 3

 There is a review clause under the ‘Open Skies’ agreement to look at the social consequences of the agreement but no request was ever done to the EU. This could present an opportunity for the Irish Government to look for specific transatlantic route support from the EU for Shannon.

European hub connection  Also needed will be a minimum of the three daily Aer Lingus services to Heathrow and daily services to two European hubs such as Paris, Schiphol or Frankfurt on a year-round basis. These routes should be supported by the route development fund if required.

Technical transit flights  Shannon gets a considerable number of technical transit flights which are fuel stops by non-scheduled US carriers such as Omni Air International. Shannon needs to be open on a 24-hour basis to grow new traffic and to facilitate these flights.  Almost 4,000 business jet flights also use Shannon on a yearly basis. These can range in size from Gulfstream aircraft and B737s right up to B747s  According to a report by the European Business Aviation Association, business aviation is a significant contributor to the Irish economy, with some 2,000 direct and indirect jobs related to the sector in 2017 and an output of €666 million.  Business jets represented 4.6% of all flight departures in Ireland in 2017, and the total number of business jet departures grew 7.3% to 7,579 in 2017 compared to 2016.  The biggest multinationals in the world use Shannon for fuel stops and to avail of the unique US pre-clearance service.  The specialist international support companies (FBO’s) such as Signature Flight Support and Universal Aviation are a key asset for Shannon’s future growth and business development. A financial support scheme should be put in place to help the FBOs target new business for Shannon.  Shannon is currently closed on nights which is a disaster for the technical transit business. Shannon has lost business to competitor airports because of the closure. Shannon must be a government designated 24-hour airport.

 To support crew changes for technical transit flights, year-round connections to the US and European hubs will also be vital.

CBP -US customs and immigration pre-clearance  Shannon airport has got US customs and immigration pre-clearance for commercial traffic and business jets, which is a huge advantage for Shannon and Ireland. Shannon was the first airport in the world to get US pre-clearance for business jets and remains the only airport outside of the Americas with this unique service. This allows passengers on business jets to fly directly to over 200 US airports after using pre-clearance in Shannon.  Year-round commercial transatlantic services with increased business jet operations are vital to enhance and grow this Shannon USP.

Irish Aviation Authority

The IAA employs almost 700 staff across six locations in Ireland. It is the regulator of aviation safety and security in this State and the primary provider of air traffic services at the three State airports and within a block of 451,000 km2 of airspace. This airspace acts as a gateway between Europe and North America with 90% of intercontinental air traffic coming through Irish airspace. As such, it is extremely disappointing that the CEO of the IAA (or his nominee) has been omitted from the Task Force.

This is all the more incomprehensible when one considers the inclusion of the Commissioner for Aviation Regulation and one of her predecessors. It is also important to note that the CAR will amalgamate with the regulatory division of the IAA in line with stated government policy. Any decisions made by this Task Force could have long term implications for the IAA and its employees, as is true for the CAR. As such, there should be equality in representation and a balance of opinion.

Recommendation: The IAA CEO (or his nominee) to be invited onto the Task Force.

The IAA has an annual turnover of almost €200 million, placing it firmly in the top 500 Irish companies. Most of this revenue is generated by users of the airspace. Each aircraft that lands at a State airport or transits through Irish airspace pays for the air traffic service. The control of charges is subject to regulation by the EU (EU Reg 2019/317). With a loss of almost 90% of traffic in the last three months, the IAA's revenue stream has currently dried up, with an income loss in the region of €18.5m. However, an EU Commission decision to delay payment of charges already owing for the last quarter of 2019, and a further proposal to defer charges for up to two years, leaves service providers with no option but to borrow while trying to maintain services for an industry showing tiny signs of recovery.

Recommendation: Financing to be approved in line with IAA Act.

We understand that DG-MOVE is proposing amendments to the regulation, which would undermine charging mechanisms, further damaging revenue streams. It is of the utmost importance that this does not happen. It is of such consequence that the professional staff organisations representing the employees of air navigation service providers across Europe have written to DG-MOVE to say they can no longer engage with DG-MOVE. This is in a sector which has been leading the way in developing social dialogue models.

The IAA's staff are intrinsic to its success. They are highly skilled and motivated. They are also not easily replaceable. Loss of staff, even voluntarily, will take considerable time to rectify. In the case of air traffic controllers, this can take at least two years. It is critical that the IAA is able to support a burgeoning aviation industry by having all elements of its service in place when and as needed.

The Irish Aviation Authority has a healthy industrial relations climate and it is important that this is maintained. The current crisis cannot be seen as an opportunity to undermine the terms and conditions of staff.

Recommendation: IAA should be assisted to retain all staff.

The Task Force must recognise that Ireland’s air traffic service provides a full service on behalf of the State irrespective of air traffic levels. This is crucial to keeping supply chains open and Ireland accessible as a major tourist destination. The Task Force should strongly resist any favouritism to any stakeholder within the sector in terms of prioritising recovery 6 arrangements. It should desist from recommendations that would see recovery for one stakeholder to the detriment of others, as this would lead to further pressure on finances and jobs thus creating a vicious circle within which each of the major stakeholders is seeking an advantage that would be devastating for both the national industry and the economy.

Recommendation: The Task Force should ensure that its recommendations are designed to ensure all sectors benefit from the recovery.

Dublin Airport Authority

To have gone from a boom situation to a complete wipe-out of business in the space of four weeks is unknown in any business mode. While the reaction of daa has been measured to date, the huge uncertainty over the future shape the aviation industry in the medium term has left the organisation in a state of trauma and its employees fearing for their future livelihoods.

The impact on employment within the daa will be felt on a much wider scale than just at Dublin and Cork airports. If 700 to 1,000 staff exit the company towns and villages in the airports hinterlands will feel the impact disproportionately to other areas where industry is probably better placed to recover.

By maintaining employment numbers at the highest possible level, will ensure that the company is prepared for the uptake in business that will happen over time. Comparing the required numbers of staff to the last time we had 21 million passengers a year is slightly misrepresenting the number that would be required to process 21 million safely through the airports in the light of the public health restrictions on people in public spaces during a global pandemic. To do this the company will require the revenue to sustain operations expenditure.

That said, as the company’s only shareholder the State has a responsibility to every citizen of to maintain State assets for this and future generations and not sacrifice their survival for the benefit of privately-owned companies whose only responsibility is to their private shareholders.

There is a suite of either revenue generation or revenue retention suggestions outlined below that would all need our shareholders support.

Revenue generation and retention

Even if aeronautical charges remain the same as 2019 there will be a huge shortfall in revenue that is required to safely operate Ireland’s two main international gateways.

We have already seen ATC charges greatly reduced at European level and state supports across Europe for airlines.

Recommendation: Airport charges to remain at 2019 levels as a minimum.

Other recommendations as follows:

In conjunction with airport charges remaining at 2019 levels state aid will be required. Apart from direct financial aid to the airports state aid to airports could also come in the shape of tax concessions from:

 Corporate tax break for a number of years  Relief of employers share of PRSI contributions

There is one area that will give airports an opportunity to generate revenue with the return of passenger numbers, namely airport retailing:

 The introduction of arrival duty free shopping as is the norm in most of the global regions outside of the EU. There is already a head of steam around this issue and is on the agenda for the ACI board. In the advent of Brexit, it is understood that the UK will have arrivals shopping. So, an absence of it in Ireland would completely negate any benefit we would derive from duty free sales between the two jurisdictions. This has a number of other attractions in that it reduces the number of bags on board, which reduces fuel burn and thus is more environmentally friendly.  Perhaps more controversial would be a deferral of payment of VAT and Duty on the sale of goods to passengers travelling within the EU. At present we operate on a duty suspended model where none of our sales are identified as duty free or duty paid until they are sold. Those goods purchased by passengers travelling within the EU then attract the appropriate excise and VAT rates, which are paid to the Revenue Commissioners. A two-year deferral of the payment of VAT and/or excise duty, with a payback over two years once recovery is achieved, would leave airports with a temporary revenue stream. In a year similar to 2019, this could have generated anywhere between €20 million and €30 million.

Cabin crew

Fórsa is the sole union recognised for cabin crew in the Republic of Ireland. The Covid-19 crisis has had devastating impact in the aviation sector, with hundreds of jobs are at risk across all the airlines. By comparison, the impact of 9/11, when most airlines had to ground their fleet for a number of days, pales in comparison. The current crisis has seen the operating schedule reduced to below 5% of a normal schedule for this time of year over the last four months. Some airlines completely grounded their fleet, and future projections are showing a very slow recovery with many factors impacting on the speed of a recovery process.

Ireland is an island and relies on connectivity for economic purposes. This sector is vital to ensure Ireland’s ability to recover economically from the current crisis. It is fundamental to our economic recovery that all airlines remain viable into the future and that employment is protected to the greatest extent possible as we exit the crisis.

Cabin crew are highly trained professional workers and their most compelling role is the safety and security of passengers and the aircraft. Cabin crew are highly trained to deal with a plethora of scenarios including survival at sea, hostage situations, fire-fighting, passenger restraint regulations, first aid issues of all types, bomb searches, decompressions, both fast and slow, and interactions with the flying public.

The Covid-19 crisis has added a further range of responsibilities where all cabin crew need to be fully trained and aware of all Covid-19 regulations, health and safety obligations, and quarantine regulations as a return to flying commences. In ensuring compliance all airlines invest in their cabin crew who are required to maintain attestations to European standards enabling them to work. Regular training is provided which is mandatory their attestation depends on time in the air. Retraining is expensive. It would be important for all airlines to have the ability to retain the maximum number of cabin crew during this period, as the sector improves. Each airline will need to have the capabilities of being able to return to the market as passenger confidence resumes, maintain cabin crew numbers, who are trained to the highest standard, to ensure a speedy return to operations.

Recommendation: To protect employment to the greatest extent possible it is essential that the TWSS is maintained and available to airlines as long as is necessary. It is also necessary to ensure any anomalies identified in the scheme are satisfactorily resolved, not least as approximately 65% of cabin crew are female.

Stress factors

Noting the gravity of the sector and expectation of the airlines need for continued redundancies, supports such as the Government Covid-19 subsidies should continue to enable employers mitigate redundancies and maintain the numbers as the aviation sector begins to open up. Pay cuts and the threat of further redundancies has put great strain on cabin crew and their families. Crew will be returning to duty with higher than normal psychological stress levels and Authorities and Airlines need to understand this and develop strategies to mitigate against this.

Recommendation: Revised risk assessments to be carried out that reflect the “new “ type of operations in a post Covid 19 operational setting emphasising the psychological risks and personal wellbeing of crew.

In-flight PPE

During the course of a normal day’s work and depending on duty and aircraft type, cabin crew will encounter anywhere between 348 and 848 passengers at close quarters. It is already accepted that the two metre social distance rule will be problematic if not impossible on an aircraft. Consideration must be given to mandatory requirements for the required PPE equipment on flights to ensure cabin crew operate in a safe environment. Cabin crew also remain concerned about access to uniforms for operations on flights. They note the guidelines for contaminated clothes and consideration should be given to expanding this for cabin crew who have to apply first aid to passengers who might be carrying the virus.

Airlines are regulated by the IAA and EASA, and it is important that pressure is brought to bear on these authorities to ensure clear regulations on PPE to instil confidence in cabin crew and the travelling public as flights resume.

Aircraft cleaning

Continued investment in additional cleaning of aircrafts is readily accepted by all airlines in the battle against Covid-19. This is to protect the health and wellbeing of workers and passengers and crucial to building confidence in a return to flying.

Recommendation: Airlines are guided in terms of aircraft operations by EASA. A clear revised Aircraft cleaning policy that meets all the regulatory health and safety and public health requirements. All cabin crew are aware of the policy and both crew and the travelling public have confidence in the policy.

Angela Kirk

Head of Division

Fórsa

22nd June 2020

Shannon Airport Passenger Figures

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Transatlantic 713556 780917 746551 574843 442147 349381 319856 287923 381150 397353 400359 428512 Britain 1162942 1286317 1253570 1139970 1062915 761789 752903 735967 711810 758371 727491 777053 Conintental Europe 655831 816676 1066630 1020437 888946 323358 269718 236118 524410 497808 461423 455891 Other Int 16 320 507 2820 869 1063 745 581 Domestic 95238 100484 89034 96836 52448 25064 1649 1393 5075 4729 6653 6192 Transit 674841 654332 464331 334623 347238 295230 280582 132799 92427 90674 155574 197114 Total 3302424 3639046 3620623 3169529 2794563 1755885 1625453 1394781 1400000 1640000 1714872 1748935 1751500 1864762 1710000

SSC/20/75/3 Agenda Item 3.1 8 June 2020

75TH SINGLE SKY COMMITTEE

23/24 June 2020

Commission Implementing Regulation on exceptional measures for the third reference period of the single European sky performance and charging scheme resulting from the COVID-19 pandemic

The Commission is in the process of addressing the impact of the COVID-19 crisis on air navigation service provision, including the preparation of related exceptional measures by the Commission for the performance and charging scheme implementation in RP3. This paper presents the envisaged exceptional measures, which are foreseen to include special rules for the application of the traffic risk sharing mechanism as well as revised performance targets at EU and local levels to reflect the latest developments due to the COVID-19 crisis. In preparing these draft measures, the Commission has considered the information and views provided by stakeholders. The stakeholder consultation comprised dedicated meetings held online by the Commission and the Performance Review Body (PRB) throughout the month of June 2020, with airspace users on 9 June 2020, with air navigation service providers on 12 June 2020 and with the professional staff representative bodies on 16 June 2020. In addition, a workshop with Member States’ experts and NSAs is organised on 17 June 2020. The Commission will report on the outcome of these meetings during the 75th Single Sky Committee Meeting. The draft Commission Implementing Regulation on exceptional measures for the third reference period of the single European sky performance and charging scheme resulting from the COVID-19 pandemic will be formally submitted to Single Sky Committee in view of a discussion and vote at a Single Sky Committee Meeting in July 2020. The Members of the Single Sky Committee are invited to express their views on the envisaged measures as outlined in this paper. In order to facilitate the preparation for Member States, the content of this paper and the discussion paper tabled for the workshop with Member States’ experts taking place on 17 June, thus just a few days before the SSC meeting, is identical.

1 BACKGROUND

Measures taken by Member States and third countries to contain the COVID-19 pandemic have resulted in a sharp reduction of air traffic throughout the EU. It is currently difficult to forecast how air traffic will recover, but it is clear that the COVID19 crisis has substantially altered the economic conditions under which air navigation services are provided during the third reference period (RP3) of the SES performance and charging scheme, covering calendar years 2020 to 2024.

The COVID-19 crisis has direct implications for the current processes and measures related to RP3, including as regards the setting of performance targets and unit rates as well as the application of risk sharing mechanisms. In order to address this exceptional situation, it is intended to introduce exceptional, temporary regulatory measures for RP3, through a new Implementing Regulation with the following objectives:

1. Resetting RP3 targets, both at EU and local level, in light of the changed operational and economic circumstances for air navigation service provision.

2. Ensuring that the adverse impact of the COVID-19 pandemic on the level of air navigation charges during RP3 is mitigated with adequate measures, in order to support the future recovery of the air transport sector.

In a recent meeting with Director-Generals for Civil Aviation, DG MOVE presented two alternative options on how to implement the above mentioned objectives. One option foresees that the revenue shortfall compared to the actual costs of providing air navigation services during 2020 and 2021 would be borne by the air navigation service providers and Member States concerned due to their unique relationship, and against the need to share the burden of the crisis between all players in the aviation value chain. However, there was a clear message that Member States would not be ready to support such an option and they instead favoured an option that would reduce the carry-overs to future years and also spread those amounts about a longer time frame.

On the understanding that the system of ex-post adjustments foreseen in the implementing rules for the performance and charging scheme was designed for limited traffic variations, it seems reasonable not to apply those adjustments unaltered in the current extreme situation and, thus, some exceptional measures are considered.

The key elements regarding those intended measures are summarized below in order to facilitate discussions during the SSC meeting.

2 SUSPENSION OF ONGOING PROCEDURES

The Union-wide targets and draft performance plans for RP3, which were drawn up and adopted in 2019 before the outbreak of the COVID-19 pandemic, do not reflect the changed circumstances and outlook in respect of air navigation service provision. It appears therefore necessary to revise the performance targets for RP3 at both EU and local level, including as regards traffic forecasts and determined costs.

In this respect, it is considered to suspend the ongoing performance planning and target setting procedures for RP3 and to initiate the development of revised Union-wide targets in accordance with the fourth sub-paragraph of Article 11(3)(c) of Regulation 549/2004.

3 REVISION OF UNION-WIDE PERFORMANCE TARGETS

The revision of Union-wide targets would be initiated by the Commission as soon as practicable, considering the availability of updated traffic forecasts. The currently envisaged process for the revision of Union-wide targets is as follows:

- National supervisory authorities would be required to provide to the Commission, by 1 November 2020, initial cost data and information about traffic forecasts for the relevant calendar years.

- The Commission would consult stakeholders on the draft revised Union-wide targets in early-2021.

- The Commission would adopt the revised Union-wide targets by 1 April 2021.

4 REVISION OF DRAFT PERFORMANCE PLANS AND TARGETS

Based on those revised Union-wide targets, Member States would be required to develop revised draft performance plans and targets for RP3. Those revised draft performance plans would have to be submitted to the Commission by 1 July 2021.

However, it is considered that only the draft performance targets for calendar years 2021 to 2024 would be subject to revision, whereas the performance targets for calendar year 2020 would remain equal to the targets contained in the latest draft performance plan submitted in 2019, given that at the time of setting those targets in early 2021, the year 2020 is already past. Also, there would not be any bonus (and penalties) from 2020 activities.

5 UNIT RATES AND RELATED ADJUSTMENTS

It results from the approach proposed above and the related timeline that the draft performance plans submitted by Member States in 2019 would apply for the setting of unit rates for 2020 and also for 2021, in accordance with existing rules on the provisional application of draft performance targets in the key performance area of cost-efficiency.

However, in order to alleviate the severe impact of the COVID-19 pandemic on airspace users during RP3, it is considered necessary to apply exceptional provisions as regards specific unit rate adjustments, as follows:

- Modification of traffic-risk sharing: With regard to calendar year 2020, the traffic risk sharing would be modified so as to reflect the fundamentally changed traffic volume due to the closure of borders and the shut-down of aviation. The modification would

take into account reduced actual costs of providing air navigation services in 2020 as a result of the COVID-19 crisis and would reduce the amounts to be recovered from airspace users in future years through carry-overs. Currently in discussion is a modification that could reduce carry-overs of around EUR 1 billion on Union-wide level. This measure would support the recovery of air traffic.

- Spread of carry-overs and unit-rate adjustment: With regard to calendar years 2020 and 2021, any carry-overs deriving from the traffic risk sharing mechanism would be spread equally over a time period of ten calendar years, starting in years 2022 and 2023 respectively. Similarly, any unit rate adjustments stemming from Article 29(5) of Implementing Regulation 2017/317 in relation to the retroactive application of cost efficiency targets in RP3 would have to be spread over a time period of ten calendar years. The purpose of both of these measures is to enable significant carry-overs to be gradually absorbed over time whilst avoiding any adverse short term impact on unit rates in RP3.

In addition, it is considered to introduce the possibility for Member States to exceptionally revise their unit rates for 2020 or 2021 during the calendar year, provided that this revision leads to a unit rate reduction.

6 ADDITIONAL MONITORING OF THE COVID-19 RESPONSE

It is expected from all air navigation service providers that they undertake the measures necessary to address the change of circumstances caused by the COVID-19 crisis, including by adapting their activities and reducing costs accordingly. Those measures would need to be transparently communicated towards stakeholders and would be subject to appropriate monitoring.

To this end, a requirement for air navigation service providers to report to the national supervisory authority on the implemented and planned COVID-19 response measures (both in numerical and qualitative terms) by 1 November 2020 could be considered. The reports would also need to be made available to the Commission for the purpose of EU level monitoring activities and in order to support the work on the preparation of revised Union-wide targets.

Submission to the Aviation Recovery Taskforce

16 June 2020

Executive Summary

• The COVID-19 pandemic has impacted the aviation sector severely and in way which is likely to have a lasting impact. Significant uncertainty around a recovery profile remains and we are a number of years away from returning to normality in aviation. The recommendations of the Taskforce for Aviation Recovery must be framed with a longer-term re-growth priority, while Government must ensure that there are no new barriers to recovery or disproportionate measures put in place. • The recommendations developed by the Taskforce for Aviation Recovery must take account of and be fully compliant with safety regulatory rules and requirements. • The IAA will continue to work with EASA and aviation stakeholders to prepare for a safe and smooth return to normal operations. Where appropriate exemptions to certain regulatory requirements will be considered, where there is no impact on safety. • As the aviation industry moves towards a return to normal, there must be no loss of focus on safety. The Taskforce should highlight that despite the financial challenges brought about by COVID-19, the safe operation of aviation must remain the main priority. • A full, fair and sustainable recovery can only be provided for when the critical roles of each part of the aviation supply chain are recognised, which includes the needs of IAA’s Air Navigation Service division. • The IAA is required to provide a full service irrespective of traffic levels and the ongoing provision of this service has been a critically important factor in Ireland’s response to COVID-19. • ANSP representatives are calling upon European policymakers to adopt a solution which supports the whole aviation sector through this crisis and does not favour one branch over another. • The IAA proposes a risk-based approach to the removal of the quarantine requirements. The IAA remains of the view that a pragmatic and sensible approach is required with respect to quarantine requirements, taking account of public health data and an assessment of tolerable risk. • The Aviation Recovery Taskforce should make an immediate recommendation to lift the quarantine requirements and replace them with the appropriate risk-based approach by 29 June rather than waiting until the report is due to the Minister on 10 July. • It is important now that the Government finalises the National Operational Guidelines for the management of airline passengers in relation to the COVID-19 pandemic. It should be published as clear guidance for the entire aviation sector including staff working within the sector and passengers relying on it. • Clear and consistent messaging around the health safety of air travel must be ensured. The promotion of domestic holidaying should not explicitly discourage passengers from travelling abroad. • The industry must first be allowed and supported to recover to a stable growth position before potential environment initiatives are developed and implemented. If these initiatives are

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implemented too soon, then they will only serve as an obstacle to growth, impacting on job and business recovery. • It is important that an industry wide roadmap or path to recovery is outlined. This should include both short term actions covering the remainder of 2020 and the National Aviation Policy will provide a good opportunity to capture longer term initiatives that reflect lessons learned during the pandemic experience. • The IAA recommends that the Government plays a leading role at European level in any political discussions around re-opening the transatlantic. There must be no dilution of the EU – US open skies agreement post COVID-19 and indeed there is an imperative now for further liberalisation in the coming years. • Policy positions and economic regulation must provide for a recovery for service providers to ensure that long term service quality can be maintained and necessary reinvestments delivered.

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Introduction The IAA welcomes the opportunity to provide a submission to the Department of Transport, Tourism and Sport (DTTAS) led Taskforce for Aviation Recovery, which has been recently established by the Minister for Transport, Tourism and Sport. This paper sets out the views of the IAA on the subject of aviation recovery and it also contains responses to the specific questions posed by the Taskforce for Aviation Recovery.

There are two key points that the Taskforce for Aviation Recovery should have due regard of as it prepares to develop an Action Plan for the Minister over the coming weeks:

1. Safety Regulation

The IAA has responsibility under the IAA Act 1993 for the safety regulation of civil aviation in Ireland. It is important that any recommendations from the Taskforce have taken account of and fully comply with extant safety regulatory rules and requirements.

2. Air Navigation Services

Air Navigation Services and Air Traffic Management services are a critical and essential part of the aviation supply chain. A full, fair and sustainable recovery can only be provided for when the critical roles of each part of the aviation supply chain are recognised and where the particular needs of each link are provided for.

General Position The IAA has noted the contents of the Aviation Recovery Taskforce Summary Information Paper and its Appendices of 12 June. It is well understood that the aviation sector has been one of the hardest hit sectors as a result of COVID-19 and it is also clear that re-opening aviation effectively is a more challenging task than re-opening many other economic sectors. However, we would highlight that it is important that an aviation recovery is not just considered in the narrow context of the sector itself; rather a fully functioning aviation sector should be seen as prerequisite of and essential to the whole economy. Ireland is more reliant on aviation for economic and social wellbeing and development than any other European country. Aviation is a key enabling sector for the wider Irish economy and it is therefore critical that any delays to the aviation recovery are avoided in order to provide the necessary support to the wider economic recovery.

A return to normal operations must be delivered fully in line with safety requirements. The IAA has been working with EASA throughout the crisis to ensure that safety remains priority within the industry. A smooth return to normal operations is required.

The IAA has been monitoring traffic levels on a daily basis since the COVID-19 crisis began and has been liaising with DTTAS accordingly. The chart below produced by EUROCONTROL in respect of air traffic levels for May 2020 compared to May 2019 indicates that Ireland has incurred a reduction in air traffic levels of 89.9%, some 5% worse than the European average. Recovery in Irish aviation is also likely to be slower than many other European countries; our economic re-opening lags behind other States while transatlantic air traffic movements which are a high proportion of Irish traffic are also likely to be slower to recover. With non-essential air traffic in Ireland largely grounded in recent months, it is imperative that a restart can be facilitated as soon as possible.

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A non-functioning aviation sector affects all participants within that sector; Air Navigation Service Providers (ANSPs), airlines, airports, ground-handling services, maintenance providers as well as the significant range of ancillary service providers to aviation.

The Summary Information Paper has not referenced the significant impact of the crisis on ANSPs, with IAA ANSP considerably exposed to the downturn and required to take extraordinary measures to maintain liquidity. ANSPs are required to provide a full service (keep the “skies open”) irrespective of traffic levels and the ongoing provision of this service has been a critically important factor in Ireland’s response to COVID-19. While the crisis has affected all aviation businesses severely, each business has had to adapt and manage its way through the crisis differently depending on its statutory responsibilities, business model and the nature of its cost base. Accordingly, one-size-fits all solutions will not work across the sector and a more nuanced approach to ensuring a fully effective aviation industry into the future must be developed.

It is also critical that the IAA ANSP is well positioned to facilitate the recovery and, as of 15 June, there have already been calls from the European Network Manager for both ANSPs and airports to ensure there is a buffer in place with regard to the outlook for traffic demand in order to avoid sudden capacity problems in the network.

The IAA would also like to bring a recent press release by CANSO to the attention of the Aviation Recovery Taskforce (Appendix A). Ultimately, CANSO is calling for policymakers to adopt a solution which supports the whole aviation sector through this crisis and does not favour one branch over another.

Notwithstanding the importance of ensuring that the needs of each part of the supply chain are provided for, it is nonetheless important that an industry wide roadmap or path to recovery is outlined.

It is becoming apparent that the impact of COVID-19 is such that there will not be a quick return to normality for aviation. In this regard, the recommendations of the Task Force must be framed with a longer-term growth priority, while Government must be conscious of the need to ensure that there are no new barriers to recovery put in place, either in the short term or the longer term as aviation rebuilds.

With regard to safety regulation, we highlight the importance of stability and certainty for aviation stakeholders. The IAA has worked with EASA to provide this, in so far as possible to aviation

Page 4 of 12 stakeholders over recent months. It is now important that as the industry looks towards a re-start, that there is no loss of focus on safety across the industry. This may be more challenging as budgets will have tightened and many aviation businesses are struggling for survival; however, it is the IAA’s view that any expenditure which drives high safety standards cannot be compromised.

Responses to specific questions For simplicity, we have responded to the three specific questions asked and have outlined specific suggestions for the Task Force’s consideration.

Short Term Actions Questions asked:

What are the short term actions needed?

What is urgent and important right here and now?

The following actions are urgently needed:

A. Removal of quarantine and other travel restrictions

The Irish aviation industry cannot recover until it is in a position to operate on a level playing field with the rest of Europe. The IAA’s submission to the Oireachtas COVID-19 Committee recommended a risk-based approach to the removal of the quarantine requirements. We again recommend that a pragmatic and sensible approach is taken, allowing for the early removal of the quarantine requirements, taking account of public health data and an assessment of tolerable risk.

Ireland is now significant outlier in terms of its quarantine restrictions for inbound passengers. It is unclear what data exists to support the requirement for quarantine restrictions. Accordingly, it is difficult to see how this approach can be justified for much longer, as the process for re-opening the rest of the economy accelerates. Many other European countries are taking a different approach to Ireland and the IAA supports a coordinated approach to re-opening aviation across Europe.

The IAA proposes a risk-based approach to the removal of the quarantine requirements. Using available data for a range of variables related to COVID-19 (for example, infections per capita, trends, reproduction rates), it will be possible to clearly identify States where the risk of contracting COVID- 19 is equivalent to or lower than the risk in Ireland. It is not justifiable requiring quarantine measures for air passengers when there is an equivalent or greater risk of contracting COVID-19 in Ireland. Taking this risk-based approach, it may be appropriate to maintain or indeed strengthen quarantine requirements for passengers who have been to certain locations within 14 days of their travel to Ireland (for example Brazil, or other countries with current high rates of transmission).

The IAA is of the view that until this issue is dealt with, Irish aviation cannot commence a sustainable process of recovery with the levels of confidence that are required. Accordingly, rather than waiting until the report is due to the Minister on 10 July, the Aviation Recovery Taskforce should make an immediate recommendation to lift the quarantine requirements and replace them with the appropriate risk-based approach by 29th June. This should involve a timely publication of countries where passengers arriving from are not required to quarantine.

B. High visibility implementation of COVID-19 Aviation Health Safety Protocol - Operational Guidelines for the management of airline passengers in relation to the COVID-19 pandemic

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The IAA and other industry stakeholders have worked with the National Aviation Facilitation Committee to develop the National Operational Guidelines for the Management of Air Passengers in light of COVID-19. The guidelines have been broadly developed in line with the EASA/ ECDC guidance document1 on the protection of passengers and staff with regard to COVID-19 as aviation re-opens.

It is important now that the Government finalises this guidance material and publishes it as clear reference guide for the entire aviation sector including staff working within the sector and passengers relying on it. The document should be endorsed by Government as the appropriate and agreed set of procedures and rules to reopen aviation safely. Similarly, it is important that all airlines operating into Ireland in addition to airports endorse the CoP and commence its implementation.

Noting the difficulties in monitoring and enforcing aspects of the Code of Practice and the importance of ensuring the relevant expert authorities are involved (e.g. HSE, HSA as relevant), the IAA is of the view that Government needs to take ownership of the Code of Practice either through the National Facilitation Committee or a working group of the Committee, in order to ensue high visibility of the National Operational Guidelines Code of Practice both among passengers and among the entities with key roles in its implementation.

C. Positive messaging from Government

With the implementation of A and B above, it is important that the public receive the appropriate messaging from government that reflects the risk based approach taken at airports and on aircraft that are designed to provide reassurances in line with up to date assessments of the epidemiological situation in other countries. In particular, communications should focus on three simple messages:

- It is safe to travel to certain destinations (full list to be developed based on the risk-based approach) - It is safe to travel on an aircraft and through an airport. - Safe means that your risk of contracting COVID-19 is no higher than the current risk in Ireland.

These messages should be communicated clearly from Government, while aviation entities should ensure that their messaging is consistent. The IAA has been concerned that in some instances there has been confusing or conflicting messages from Government with regard to the re-opening of aviation and the ability to travel. The importance of clear and consistent messages with the authority of Government behind it will be very important in driving consumer confidence and passenger demand.

Finally, the promotion of domestic holidays will undoubtedly be welcome by the hospitality and tourism sectors in Ireland but these messages should not explicitly discourage the public from travelling abroad, as this message will conflict the importance of building passenger confidence to travel.

1 https://www.easa.europa.eu/newsroom-and-events/press-releases/easaecdc-issue-joint-guidelines-assure- health-safety-air-travel

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Medium Term Actions Specific Question:

What is needed for the medium term, 3-6 months?

The medium-term requirements are identified on the basis that the short term requirements set out above have been implemented and the aviation sector is commencing a process of recovery from the COVID-19 crisis. It also assumes that widespread travel restrictions are not reinstated (no “second wave” of infections) and that reliable data on a range of key metrics starts to emerge (e.g. traffic forecasts, economic data, passenger confidence etc).

A: Develop new National Aviation Policy

Prior to COVID-19, a new National Aviation Policy (NAP) was in the early stages of planning by DTTAS. The previous policy, published in 2015, was considered to be out-of-date in many areas and a full redevelopment was required in order to appropriately position Ireland’s aviation sector for the next number of years.

IAA agrees with the requirement for the development for a new National Aviation Policy, with the necessity underlined by the widespread impact on the aviation sector by COVID-19. It will only be possible to develop accurate plans once there is reliable data and modelling available. Current indications are that, with the economy re-opening, this data should start to be available towards the end of the year. Commencing the development of this new national policy in the medium term (3 – 6 months) will be an important signal to industry that Government is prepared to work with it to establish the longer-term requirements for the industry to fully emerge and recover from COVID-19.

B: Roadmap to recovery

The new NAP should set out a vision of how the aviation sector can recover from COVID-19 and return to a position of growth. The likelihood of a fast recovery is quickly diminishing with some indications that it may take 4 - 5 years for the aviation sector to fully recover. Therefore, it will therefore be important that the policy is realistic rather than aspirational. This means that policy should only be considered or implemented if it can be afforded by the industry at this time and if it does not create any additional barriers to recovery. Policy positions should be designed to ensure the industry can stabilise, commence growth and support the Irish economy.

Accordingly, the IAA is of the view that the NAP should include a longer-term roadmap for aviation recovery. This should at a minimum be a five-year plan, aiming to incrementally support the rebuilding of the industry, rebuilding of passenger confidence and where appropriate redesign of the aviation industry in a post COVID-19 environment. COVID-19 has changed the aviation environment and it is important that national policy fully considers this rather than simply treating the COVID-19 pandemic as a once off or short-term event. However as per our earlier comments, aviation safety must remain the core focus of policy. The industry cannot afford any degradation of safety performance and so continued focus must remain on safety.

C: Supports to aviation and tourism industry

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If the short-term measures required for aviation are about re-starting the industry in a timely manner, the medium-term measures must be about a more detailed assessment of the needs of each part of the aviation sector, in order to assist (or not hinder) a return to growth. This will allow for the development of targeted assistance, initiatives or financial measures.

As a clearer picture emerges of the COVID-19 impact on the aviation and tourism sectors over the next 3 – 6 months, more reliable information will become available on a key range of issues. There will be a better understanding of which routes have been most affected, whether business or leisure travel is recovering, which specific businesses are worst affected and whether the recovery is evenly dispersed. Indeed, as passengers return it should be possible to build a picture of passenger expectations post COVID-19.

All of this information will allow for Government to consider appropriate financial, taxation or other support measures required to assist a return to growth. For example, the lower VAT rate on the hospitality sector was an effective measure to assist the recovery of tourism and hospitality after the last financial crisis. A similar measure for this sector could assist both tourism and aviation.

Other relevant targeted measures could include grant support for reinvestments or for staff training/ retraining programmes, maintaining or enhancing safety standards, liquidity assistance or other financial mechanism to support re-growth.

Furthermore, the IAA is concerned that while many aviation businesses may survive the immediate impacts of COVID-19 over the summer and autumn of 2020, many businesses may have exhausted cash reserves by the winter or may become insolvent if the recovery is not sustained. If the industry is confident that there will be appropriate supports in place to get many of these businesses through the winter 2020/21 (the off-peak season), it may allow for many businesses to return to growth in summer 2021.

D: Reopening the North Atlantic

Reopening regional (intra-European) travel in July and August is a realistic target for the aviation sector and Governments across Europe. It is clear that re-opening travel for destinations outside of Europe will take longer and is more politically complex. However, it is important that there is a clear leadership position taken by Ireland to prioritise the re-opening of transatlantic traffic in particular from September onwards.

In recent years, transatlantic traffic from Ireland had increased significantly, with the benefits of the EU-US open skies agreement becoming clear. Direct flights from Dublin, Shannon and Cork to a wide range of US and Canadian destination where available, with significant benefits for trade and connectivity. Dublin airport in particular was emerging as an important transatlantic hub, which in turn drove further intra-European connecting traffic. It is important post COVID-19 that the connections and trade routes built up in recent years can be re-opened as soon as possible.

In order to achieve this, the IAA recommends that the Government plays a leading role at European level in any political discussions around re-opening the transatlantic. There must be no dilution of the EU – US open skies agreement post COVID-19 and indeed there is an imperative now for further liberalisation in the coming years.

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Longer Term Actions Specific Question:

What do we need over the next 2-3 years?

In the longer term, the key objective must be to regrow the aviation industry in Ireland to a point where sufficient profits are made to reinvest in growth, industry resilience and sustainability. It is expected that this will take a number of years, most likely beyond the 2 – 3 years timeframe of the question, but up to 5 or more years. In simple terms, aviation businesses need the flexibility and opportunity to regrow, put their businesses on a more sustainable footing, make investments to support the quality of future services and build resilience against any other future shocks.

Notwithstanding the consensus surrounding the need for a new National Aviation Policy, it is crucial that there is a focus on the longer-term process of rebuilding the industry as follows:

A: Revised approach to economic regulation focussed on stability and regrowth

At present, almost all businesses in the aviation sector are facing considerable financial losses, cutting costs intensively and focussed solely on survival. It is precisely at times like this that the principles of economic regulation, in particular certainty, are important. The IAA does not agree with proposals by the European Commission which require a new Implementing Regulation for the ATM Performance and Charging Regulations as this will ultimately result in the IAA being unable to recover the true cost of delivering its statutory responsibilities. This represents considerable inconsistency from European policymakers who are not amending the EU 261 Regulation. There is a real threat of ANSPs facing liquidation across Europe, including those who have followed EU initiatives to become commercial entities, but the European Commission is nonetheless prioritising a policy that will ultimately be negative for ANS service provision across Europe.

Economic regulation must now focus on ensuring the financial stability of service providers, as well as continued high-quality performance in the delivery of their statutory roles. Policy makers, regulators and service providers all have critical roles to play, to ensure that recovery is prioritised. IAA would be concerned if there is any attempt to “use” the crisis to re-baseline costs; Policy makers and Regulators should resist this as it will only result in a longer-term degradation of service.

Furthermore, and consistent with this, the Government must ensure that there is an investment and growth climate for all aviation businesses for the longer term.

B: Sustainability

The aviation industry pre COVID-19 has commenced a process of planning and adjusting to meet carbon emissions requirements. While the short-term focus is on business survival, it is important that the longer term focus on a more sustainable and carbon conscious industry is not lost. However, the IAA is of the view that appropriate environmental initiatives must be timed correctly. Accordingly, the industry must first be allowed and supported to recover to a stable growth position before potential environment initiatives are developed and implemented. If these initiatives are implemented too soon, then they will only serve as an obstacle to growth, impacting on job and

Page 9 of 12 business recovery. It is our view that the Task Force must make a clear recommendation to Government in this area. This can be included as part of any longer-term roadmap highlighted above.

C: Connectivity

Re-opening transatlantic connectivity must be priority in the coming months. However, in the longer term, re-establishing existing routes, developing new routes and connectivity both intra-European and outside of Europe must be a priority. In particular, routes to Asia, middle East and South America should be explored while the further liberalisation of the EU – US open skies agreement will allow for transatlantic traffic to return to growth over time.

D: Safety Regulation

Safety must remain the key priority of the aviation sector post COVID-19. It is therefore important that as the financial position of aviation companies is weakened, there is no loss either internally or at policy making level on the need for continual focus on safety performance.

A key challenge emerging from the COVID-19 crisis is the funding of safety regulation. This will need to be considered in detail post COVID-19 in order to ensure that the safety regulator remains on a stable, financial footing and there is no loss of effectiveness of safety regulatory oversight.

Conclusion The IAA welcomes the opportunity to provide this submission to the Aviation Recovery Taskforce. The challenges facing all businesses in the aviation sector over the next few months and into the longer term have never been greater. The IAA’s submission focusses on ensuring that safety standards the implementation of safety rules remain prioritised across all aviation businesses, as the industry starts to return to normal operations. However, given the recovery profile is unclear, it is important policy focuses on rebuilding the industry. Short term initiatives are necessary to ensure that the industry re- starts as soon as possible, while over time it will be necessary to ensure that targeted measures are delivered to facilitate growth. All parts of the supply chain have been affected by the crisis and so it is important that all parts are treated equally, to ensure a whole industry recovery.

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Appendix A: CANSO proposes aviation crisis recovery plan for Europe

Brussels, 12 June 2020 – The aviation sector is faced with an unprecedented crisis which has had a devastating impact on revenues and put the industry’s collective survival into question. With traffic levels in Europe at around 15% of what they were last year, the Civil Air Navigation Services Organisation (CANSO) is calling for a solution to the financial burden of the crisis caused by the decline in air traffic that will work for the whole aviation sector – airlines, airports and air navigation service providers (ANSPs).

ANSPs are in the unique position of being mandated to keep the skies fully open and sectors staffed even when traffic levels and the related ANSP revenues are at a record low. They are also responsible for maintaining the well-being of their staff working in air traffic control centres during a public health emergency.

Many airlines have already been promised state aid or are negotiating government support. According to IATA’s latest figures this already amounts to $30 billion (€26.4 billion) within Europe alone. At the same time, the airlines have been allowed to defer their payment of air traffic control fees due to a significant shortfall in passenger revenue.

By contrast, the state financing promised to ANSPs has been far more limited, and they must now seek loans. Although CANSO members are making significant cuts to their cost base (e.g. furloughing staff, voluntary salary cuts, postponing/cancelling non-vital investments), these are not enough to cover the financial gap.

“When it was conceded to allow airlines to defer payment of their fees to our members in April, we saw this as a one-off action rather than a permanent mechanism to transfer the financial burden from the airlines to the ANSPs. We understand the pain our customers are in, but in the future, we need to return to the position where airspace users pay for the essential service provided by ANSPs,” said CANSO’s European Director, Tanja Grobotek. “We strongly contest any notion that our members are in a position to provide financing to the airlines.”

CANSO therefore calls for a European, industry-wide recovery plan to get planes flying again. This should be based on two pillars.

1. Financial support from the EU for the whole aviation sector - CANSO calls on the EU to provide whatever financial support is needed to get ANSPs, airlines and airports through the crisis period. This should be done in a holistic way which does not favour one branch of aviation over another and is potentially accessible to all.

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2. A temporary revision of the EU Performance and Charging Scheme - Air traffic control services fees are determined by the EU’s Performance and Charging Scheme, which sets performance targets for ANSPs and regulates how they are paid by airlines. It is now under severe strain due to the drastic fall in traffic. CANSO therefore calls for a temporary solution that works for both the ANSPs and the airlines until traffic recovers to levels that make the Scheme sustainable again. Airlines should remain legally liable for payment of fees for the duration of this crisis, just as ANSPs should remain legally liable to provide a service, EU support is required to cover the gap between what the airlines can afford to pay and what they owe the ANSPs for their services.

CANSO underlines that this support must be temporary. CANSO cannot sign up to any solution which puts future ANSP revenues, and thus their service provision, in any doubt. Many CANSO members are now trying to secure additional financing on commercial terms to preserve liquidity, and this hinges on a guarantee of future revenues. Any further legal uncertainty regarding the Performance and Charging Scheme could jeopardise the efforts to secure this crucial funding.

CANSO therefore calls on EU policymakers to adopt a solution which supports the whole aviation sector through this crisis and does not favour one branch over another.

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Evidence to the Irish Government’s Taskforce for Aviation Recovery

1. Background This document provides evidence on behalf of the International Air Transport Association (IATA) to the Irish Government’s Taskforce for Aviation Recovery.

IATA has been widely involved in aviation recovery matters at ICAO, EASA, European and individual state level and we very much welcome the initiative in Ireland to launch this Task Force. In addition to offering this evidence, IATA would be happy to present and elaborate to the Task Force on any of the matters discussed below. 2. About IATA The International Air Transport Association (IATA) is the trade association for the world’s airlines, representing some 290 airlines and 82% of global air traffic. IATA supports many areas of aviation activity and helps formulate industry policy on critical aviation issues to drive a safe, secure, and sustainable industry. For more information on IATA and its work visit www.iata.org. 3. The impact of Coronavirus on Aviation IATA’s latest analysis, published on 3 June, shows that global demand for air services is beginning to recover after hitting a low point in April. Global passenger demand in April (measured in revenue passenger kilometres), plunged 94.3% compared to April 2019, as the COVID-19-related travel restrictions virtually shut down domestic and international air travel. The effect in Europe was particularly severe with European carriers’ April demand falling 99.0%, a sharp decline from the 53.8% decline in March. Capacity dropped 97% and load factor shrank by 58 percentage points to 27.7%. This is a rate of decline never seen in the history of IATA’s traffic series, which dates back to 1990.

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More recently, figures show that daily flight totals rose 30% between the low point on 21 April and 27 May. This is primarily in domestic operations in the Asia Pacific region and off of a very low base (5.7% of 2019 demand). While this uptick is not significant to the global dimension, especially in Europe, of the air transport industry, it does suggest that the industry has seen the bottom of the crisis, provided there is no recurrence. In addition, it is the very first signal of aviation beginning the likely long process of re-establishing connectivity.

4. Outlook for the global air transport industry

Despite the first signs of a modest recovery in demand, the financial outlook for the global air transport industry shows that airlines are expected to lose $84.3 billion in 2020 for a net profit margin of -20.1%. Revenues will fall 50% to $419 billion from $838 billion in 2019. This means, based on an estimate of 2.2 billion passengers this year—airlines will lose $37.54 per passenger. In 2021, losses are expected to be cut to $15.8 billion as revenues rise to $598 billion.

In Europe demand is expected to drop 56.4% (in revenue passenger kilometres) resulting in a net loss of $21.5bn.

4.1. 2020 Main Forecast Drivers

Passenger demand evaporated as international borders closed and countries locked down to prevent the spread of the virus. This is the biggest driver of industry losses. At the low point in April, global air travel was roughly 95% below 2019 levels. Traffic levels (in Revenue Passenger Kilometre) for 2020 are expected to fall by 54.7% compared to 2019. Passenger numbers will roughly halve to 2.25 billion, approximately equal to 2006 levels. Capacity, however, cannot be adjusted quickly enough with a 40.4% decline expected for the year.

Passenger revenues are expected to fall to $241 billion (down from $612 billion in 2019). This is greater than the fall in demand, reflecting an expected 18% fall in passenger yields as airlines try to encourage people to fly again through price stimulation. Load factors are expected to average 62.7% for 2020, some 20 percentage points below the record high of 82.5% achieved in 2019.

Costs are not falling as fast as demand. Total expenses of $517 billion are 34.9% below 2019 levels but revenues will see a 50% drop. Non-fuel unit costs will rise sharply by 14.1%, as fixed costs are spread over

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fewer passengers. Lower utilization of aircraft and seats as a result of restrictions will also add to rising costs.

Fuel prices offer some relief. In 2019 jet fuel averaged $77/barrel whereas the forecast average for 2020 is $36.8. Fuel is expected to account for 15% of overall costs (compared to 23.7% in 2019).

Cargo is the one bright spot. Compared to 2019, overall freight tonnes carried are expected to drop by 10.3 million tonnes to 51 million tonnes. However, a severe shortage in cargo capacity due to the unavailability of belly cargo on (grounded) passenger aircraft is expected to push rates up by some 30% for the year. Cargo revenues will reach a near-record $110.8 billion in 2020 (up from $102.4 billion in 2019). As a portion of industry revenues, cargo will contribute approximately 26%--up from 12% in 2019.

4.2. Reduced losses in 2021

With open borders and rising demand in 2021, the industry is expected to cut its losses to $15.8 billion for a net profit margin of -2.6%. Airlines will be in recovery mode but still well below pre-crisis levels (2019) on many performance measures:

• Total passenger numbers are expected to rebound to 3.38 billion (roughly 2014 levels when there were 3.33 billion travellers), which is well below the 4.54 billion travellers in 2019. • Overall revenues are expected to be $598 billion which would be a 42% improvement in 2020, but still 29% below 2019’s $838 billion. • Unit costs are expected to fall as fixed costs are spread across more passengers than in 2020. But the continued virus control measures will limit the gains by reducing aircraft utilization rates. • Cargo’s enlarged footprint in the air transport industry will remain. Cargo revenues will reach a record $138 billion (a 25% increase on 2020). That is about 23% of total industry revenues, roughly double its historical share. Air cargo demand is expected to be strong as businesses restock at the start of the economic upturn, while a slow return of the passenger fleet will limit the growth of cargo capacity, and keep cargo yields steady at 2020 levels. • Jet fuel prices are expected to rise to an average of $51.8 per barrel for the year, as global economic activity and oil demand rises. While that will add some cost pressure on airlines, the price per barrel is similar to 2016 ($52.1) and will still be the lowest since 2004 ($49.7).

Passenger revenues will be more than one-third smaller than in 2019 and airlines are expected to lose about $5 for every passenger carried. The cut in losses will come from re-opened borders leading to increased volumes of travelers. Strong cargo operations and comparatively low fuel prices should also give the industry a boost. Competition among airlines is likely to be even more intense. The challenge for 2022 will be turning reduced losses of 2021 into the profits that airlines will need to pay off their debts from COVID- 19 crisis.

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4.3. A challenging recovery

Although losses will be significantly reduced in 2021 from 2020 levels, the industry’s recovery is expected to be long and challenging. Some factors include:

• Debt Levels: Airlines entered 2020 in relatively good financial shape. After a decade of profits, debt levels were relatively low ($430 billion, roughly half annual revenues). Vital financial relief measures by governments have kept airlines from going bankrupt but have ballooned debt by $120 billion to $550 billion which is about 92% of expected revenues in 2021. Further relief measures should be focused on helping airlines to generate more working capital and stimulating demand rather than further expanding debt.

• Operational efficiencies: The global measures agreed for the industry re-start, for the period that they are implemented, will significantly change operational parameters. For example, physical distancing during embarkation/disembarking, more deep cleaning, and increased cabin check will all add time to operations which will decrease overall aircraft utilization. • Recession: The depth and duration of the recession to come will significantly impact business and consumer confidence. Pent-up demand is likely to drive an initial uptick in travel numbers but sustaining that is likely to require price stimulus and that will put pressure on profits. • Confidence: Travel patterns are likely to shift. The gradual opening up of air travel is likely to be progressive, starting with domestic markets, followed by regional and, lastly, international. Research suggests that some 60% of travellers will be eager to recommence travel within a few months of the pandemic coming under control. The same research also indicates that an even greater percentage of potential travellers until their personal financial situation stabilizes (69%) or if quarantine measures are in place (over 80%).

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5. Actions needed to support aviation’s recovery 5.1. Short-term actions needed (1-3 months) 5.1.1 Implementing Health Guidelines To meet the unprecedented challenge restarting an industry that has essentially ceased to operate across borders while ensuring it does not become a vector for the spread of COVID-19, IATA and ACI jointly proposed a roadmap for restarting aviation (link), aimed at providing the confidence that governments are looking for to enable the lifting of travel restrictions and border controls while restoring the trust that travellers need to return to flying.

These guidelines were widely referenced in the ICAO and EASA discussions and IATA has welcomed the joint Guidelines from EASA and ECDC as well as from ICAO for the safe restart of air transport – and we are calling on all States to apply these guidelines in a harmonized, efficient and mutually recognized manner. The guidelines are focused on a safe restart of air transport in Europe and include much of the input IATA and other industry stakeholders have provided. The industry is therefore actively supporting European States to achieve this goal. By implementing health safety protocols that provide a layered, risk-based approach to bio-security, it will be possible to mitigate to the greatest extent possible the risk of spreading the virus while restoring the confidence to travellers. By implementing the measures, States can show leadership to the global aviation community and strike a good balance between sensible enhanced measures for public health, while enabling the industry to restart viable aviation services.

5.1.2 Lifting quarantine Ireland’s quarantine policy remains a major blocker to any meaningful restart. We have serious reservations about quarantining all arrivals, irrespective of where passengers are originating from. This approach will not only make most air services unviable by severely impeding demand, it will also have serious consequences for Ireland’s tourism & hospitality industries, and any sector of the economy which relies on air connectivity for their supply chains, recruitment and exports.

IATA strongly urges the government to find an alternative to maintaining arrival quarantine measures as part of post-pandemic travel restrictions. IATA’s April survey of recent air travellers (globally) showed that 86% of travellers were somewhat or very concerned about being quarantined while traveling, and 81% of recent travellers would not consider travelling if it involved a 14-day quarantine period.

To protect aviation’s ability to be a catalyst for the economic recovery, it is important not to make that prognosis worse by making travel impracticable with quarantine measures. Solutions are needed addresses two challenges. It must give passengers confidence to travel safely and without undue hassle. And it must give governments confidence that they are protected from importing the virus. IATA’s proposal is for a layering of temporary non-quarantine measures until we have a vaccine, immunity passports or nearly instant COVID-19 testing available at scale.

IATA’s proposal for a temporary risk-based layered approach to provide governments with the confidence to open their border without quarantining arrivals includes:

• Preventing travel by those who are symptomatic with temperature screening and other measures

• Addressing the risks of asymptomatic travellers with governments managing a robust system of health declarations and vigorous contact tracing.

• The mutual recognition of agreed measures is critical for the resumption of international travel. This is a key deliverable of the EASA-ECDC and ICAO(CART) guidelines.

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Early and full implementation of the health guidelines, as outlined in section 5.1.2 would be an important measure to allow the full lifting of quarantine.

5.1.3 Slot Alleviation Slot alleviation has been granted for the northern summer 2020 season at all 197 slot coordinated airports globally, with similar flexibility being sought at Level 2 airports. The suspension of the 80-20 rule has been critical in enabling airlines to plan their schedules with maximum flexibility during a time of great uncertainty. It has provided airlines and airports the certainty that the routes and network they have invested in will be valid next summer, protecting vital connectivity and preparing the way for recovery.

Aviation’s recovery in Q3 and Q4 of 2020 and 2021 is likely to be very slow and demand will be difficult to forecast, meaning an extension of the existing waiver may be necessary for the Northern 2020 Winter season. We are pushing for the decision to be made before the end of July.

The extension to the alleviation is necessary because this enables the airlines to react according to their planning timeframes and best make use of the slot flexibility by aligning demand to their schedule and changing flying patterns to maintain connectivity where possible. The extent of the full season alleviation also provides the much-needed framework to support recovery as carriers build back their schedule on their existing slots, over weeks and months. Services will be recovered as the demand builds back, likely supporting a gradual restarting of the services. This would mean that airlines could more quickly get back to supporting economies and providing consumers with the services they want.

As the medical threat of COVID reduces in Europe the business outlook remains bleak and airlines will be operating in a unknown environment. Allowing them the maximum flexibility to launch (and remove) services to test demand will be necessary and a full winter wavier will provide extra assurance to airlines.

The aviation industry is united in its desire to return to the existing slot use rules as soon as industry conditions make it possible. 5.2. Medium-term actions needed (3-6 months) 5.2.1 Fiscal Support Over the past decade, governments benefited from the solid performance of the airline industry with airlines and their customers generating $111 billion per year on average in tax revenues. During the COVID-19 crisis, airlines sought support from governments to help survive and overcome this period of unprecedented turmoil. As of mid-May, airlines worldwide are estimated to have received $123bn of government aid.

Support from governments has taken a variety of forms, including capital injections, the provision of loans, deferring the payment of taxes and reducing tax liabilities. Some governments have also provided wage subsidies to preserve jobs. Notwithstanding action taken at the European level, the Irish government has so far provided limited alleviation on fuel costs and fees, representing a cost avoidance of US$0.016 million. IATA is concerned that Ireland risks falling behind other economies by so far deciding against a bespoke package of support for the Irish aviation industry.

• In Denmark, DKK1.5 billion state guarantees for the national airline, while other airlines can apply from the general state guarantee fund • In Finland, the government has agreed to provide a state guarantee of €600 million to assist the national carrier • In France, the Government has set out €700 million of tax aid to airline sector. • New Zealand’s government will open a NZ$900 million (US$580 million) loan facility to the national carrier as well as an additional NZ$600 million relief package for the aviation sector.

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• In Norway: o The Government has suspended the air passenger tax (equivalent to Air Passenger Duty) until 13 October o The Government is fully compensating airports for the loss of airport charges o A domestic airline receives NOK40 million (£3.1 million) per month to maintain critical routes until further notice o The state offers loan guarantees of NOK6 billion (£472 million) to airlines registered in Norway • In Spain, a credit line of up to €400 million for travel sector, granted by the state-owned Credit Corporation • In Sweden, Swedish airlines are offered credit guarantees worth a maximum of SEK5 billion.

A full list of relief measures being implemented by governments can be accessed here.

As aviation seeks to rebuild demand and contribute to economic recovery more broadly, measures to support airlines can help to boost demand while allowing airlines to remain financially in a period when costs are not falling as fast as demand increases. Airlines will be key facilitators to economic recovery and support measures would also help avoid broad economic damage by ensuring that airlines can rapidly scale-up operations.

We have recommended to governments globally to consider the following measures which include:

• Direct financial support to passenger and cargo carriers to compensate for reduced revenues and liquidity attributable to travel restrictions imposed as a result of COVID-19; • Provision of loans, loan guarantees and support for the corporate bond market by the Government or Central Banks. The corporate bond market is a vital source of finance, but the eligibility of corporate bonds for central bank support needs to be extended and guaranteed by governments to provide access for a wider range of companies. • Tax relief measures to mitigate the loss of revenues due to the unprecedented levels of demand reduction. This would include reductions or deferrals of all aviation taxes and regulatory charges for the remainder of 2020 (including inflationary adjustments) without overcharges or penalties; rebates on payroll taxes paid to date in 2020 and/or an extension of payment terms for the rest of 2020, along with a temporary waiver of ticket taxes and other government-imposed levies such as APD. • Market stimulus to reboot demand and accelerate market recovery.

5.2.2 Restoring confidence As travel and transport start to become the normal again it will be important for the Irish Government to implement measures to restore confidence in air travel. Communication to passenger, both during travel and before travel by way of mass media, advertising and social media will be essential to show passenger that air travel is safe. The Irish Government should work with industry to ensure aligned and consistent and continuous messaging is provided to passenger and the general public.

A key part of restoring confidence this will be to encourage inbound travel to Ireland and central to this will be to ensure that Ireland is seen as open for business and that the domestic transportation and hospitality business is open and taking measures to ensure consumers from outside Ireland are confident to visit. This could also extend to ensuring that the Irish travel insurance market is open and accessible for corporate and leisure passengers and that cover would apply whilst in Ireland.

5.2.3 Stimulating demand In addition to the fiscal support outlined above Ireland should give consideration to a range of incentives to support a restart of travel demand. These could include direct support and destination based incentives to

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boost travel and tourism demand including enhanced destination marketing for Ireland as well as investigating visa facilitation matters including potentially simpler and cheaper visa procedures for inbound visitors.

5.3. Longer-term actions needed (2-3 years) The recovery of the industry, as outlined above, will not be a fast rebound and it will take a sustained effort by industry and governments to foster growth. Actions in the longer term are, by definition, strategic.

Although priority must be given to shorter and medium term measures to secure the future of the industry, in the longer term consideration should be given by the Irish Government to launch, in collaboration with industry, an aviation strategy that highlights they key issues for long term growth as well as including the policy and industry actions needed.

Topics that could be considered as part of such a strategic review could include:

• Green growth - promoting a move to lower carbon future for aviation

• Infrastructure – ensuring adequate airport and airspace capacity, sufficient to meet demand but delivered cost effectively

• Technology & innovation – promoting and incentivising the use of the latest technology in all aspects of the business and fostering innovation in aviation

• Fiscal treatment of aviation – easing the tax and fiscal burden on the industry to allow for long term growth

• Connectivity - ensuring Ireland remains connected globally and take advantage of its unique position for the North Atlantic

• Regulation – undertaking a root and branch review of aviation regulation with a view to minimising the regulatory burden on the industry

• Financial services to aviation - Taking advantage of the fact that Ireland has become a unique centre of aviation finance.

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submission to

The Aviation Recovery Taskforce

16th June 2020

The Irish Travel Agents Association welcomes the opportunity to make a written submission to The Aviation Recovery Taskforce outlining our proposals on:

1. The short term actions needed for recovery of the travel industry, including what is urgent and important right here and now. 2. What is needed for the medium term, 3‐6 months. 3. What is needed over the next 2‐3 years.

Short term actions needed

1. Removal of two weeks quarantine

The current request to self‐isolate on arrival into Ireland is a massive deterrent to anyone considering booking a holiday or travelling from Ireland. Whilst not a mandatory requirement, the fact that it is constantly referenced and the very high level of compliance on the part of residents of the State means that travel will not recommence in any meaningful volume until this requirement to quarantine or self‐ isolate is removed. https://www2.hse.ie/file‐library/coronavirus/covid‐19‐passenger‐locator‐form.pdf

2. a. Change of DFA guidance on travel

The current Department of Foreign Affairs (DFA) guidance is absolutely clear “The Irish Authorities advise against all non‐essential travel overseas until further notice”. This an absolute deterrent to anyone considering booking a holiday or travelling for any reason from Ireland. Travel insurance is invalidated if a consumer travels overseas contrary to DFA advice. This advice needs to be changed in line with the other 26 member states. https://www.dfa.ie/travel/travel‐advice/

Irish Travel Agents Association submission to the Aviation Recovery Taskforce 16 June 2020 1 2.b. Consistency of travel advice

We also need there to be joined up thinking between Government Departments around Travel Advice. From July 2020 airlines will restart flying and yet DFA advice is not to travel. This serves to confuse the consumer and they lose their right to a refund if the flight operates contrary to Government advice. If Government do not want to stop airlines flying then they need to provide a compensation process for consumers so they are not caught in the middle between the airlines and Government advice.

3. Opening of routes / follow guidance of EU

On 11 June, the EU Commission issued a communication document on the lifting of travel restrictions within the EU from 15 June. The Government of Ireland said on 12 June that it will not be following these guidelines. At a press conference on 12 June, following a cabinet meeting, the Taoiseach said “Don’t travel off the island for tourism, don’t come to the island for tourism; anyone who is arriving here, ‐ even for an essential reason – will have to fill‐out a passenger form, and will be strongly advised to self‐quarantine for 14 days.”

We need the Irish Government to open up air routes within the EU in a safe, planned and phased manner to allow citizens travel safely and to allow airports, airlines, hotels, tourist attractions and the outbound travel industry get back to business. Outbound and inbound travel combined accounts for almost 250,000 Irish jobs. This is the single largest indigenous industry in the State. The EU is opening up travel between member states and Ireland is standing alone and refusing to follow EU guidelines whilst jeopardising the jobs of 250,000 Irish residents. https://ec.europa.eu/info/sites/info/files/communication‐assessment‐temporary‐restriction‐non‐essential‐ travel_en.pdf

4. Need to build consumer confidence

In order for consumers to feel safe about travelling from July onwards there need to be a co‐ ordinated, sustained, and informative set of guidelines to re‐establish confidence for them to restart booking travel and travelling. This should include airlines, airports, hotels, tourist boards and other stake holders to work together on health and safety initiatives that will restore and rebuild consumer confidence.

The DFA could host such information as they are the “go‐to” website for travel advice and it could be incorporated into the Travelwise App. https://www.dfa.ie/travelwise/

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Irish Travel Agents Association submission to the Aviation Recovery Taskforce 16 June 2020 2 Medium term (3‐6 months) actions needed

1. Industry supports including COVID payments & other financial supports important to travel agents ‐ securing employment & sustainability

The travel industry in Ireland has had zero cash flow since March 2020. It is in fact in negative cash flow as it continues to pay rent, rates and services not to mention salaries not covered by the current wage subsidy scheme. Sales are approximately 98% down since March and the key summer months have been lost with no immediate sign of travel resuming. Employers in the industry are going to need the wage subsidy scheme extended to the end of 2020 or fixed capital grants for retaining jobs through to year end 2020. There is no opportunity to earn back this lost income so the supports have to take the form of subsidies and grants and not loans.

2. Health & safety guidance to build consumer confidence to overcome nervousness of travel

3. Travel insurance

Since the outbreak of COVID‐19 in Ireland, travel insurers have either withdrawn (in the case of existing policies) or excluded (in the case of new policies) COVID ‐19/pandemic risks, resulting in travellers having little or no recourse to the travel insurance policies they purchased.

There is widespread uncertainty surrounding the containment of COVID‐19 into the future.

Travellers are concerned that they could be faced with renewed lock‐downs (full or partial); non‐ essential travel bans being re‐imposed; work‐place quarantines on return from travel; or indeed contracting COVID‐19 themselves. Should any of these scenarios arise a trip may have to be cancelled or curtailed. In order for consumers to start booking travel again, they will need to feel secure that they will be able to recover their money through travel insurance.

The ITAA urges the Taskforce to work with the FSBO and Insurance Ireland to ensure the availability of suitable travel insurance policies. Travel insurance policies that actually cover COVID‐19 cancellation risks during the recovery stage will play an extremely important role in the recovery of the aviation/travel sector.

Irish Travel Agents Association submission to the Aviation Recovery Taskforce 16 June 2020 3 4. Card Services Industry ‐ Merchant Acquirers

ITAA members have reported instances of Merchant Acquirers freezing payments due to them thereby exacerbating already challenging cash flow positions. Reports have also been received of credit card facilities being revoked or suspended, without any notice or basis being provided. Merchant Acquirers should be called upon to refrain from taking reactionary steps, which have a paralysing effect on businesses.

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Irish Travel Agents Association submission to the Aviation Recovery Taskforce 16 June 2020 4 Long term (2‐3 years) actions needed

1. Pandemic Refund Guarantee Fund

The establishment of an EU‐wide Pandemic Refund Guarantee Fund would provide confidence for the aviation/travel sector and travellers alike, that proper provision has been made for the refund of travellers’ monies in the event of future pandemics. Such a fund could be administered by the various NEBs. A per traveller contribution, which would most likely be minimal in terms of value, when compared to the premium paid for a travel insurance policy, could be collected at time of booking – giving travellers peace of mind.

Such a fund could also be established at a national level.

2. Airline Insolvency Protection

The pandemic has brought into sharp focus the difference between the financial protection provided to travellers by organisers of packages as opposed to airlines. In line with the requirements of the Package Holidays and Travel Trade Act, 1995, travellers’ monies are protected when they purchase a package, by to have insolvency protection arrangements put in place by travel agents and tour operators. Consumers’ monies held by airlines are not protected in the event of the airline’s insolvency. Airline insolvency protection measures should be implemented for a return of consumer confidence and demand for travel.

3. Stakeholder Working Group

What is evident from the initial experience of COVID‐19 is that there must be a better way to manage the impact of a future pandemic on aviation/travel businesses and their customers. The ITAA recommends the establishment of a stakeholder working group comprising the representatives of airlines, ferry companies, cruise companies, travel agents, tour operators, travel insurance industry, credit card companies, the Consumer and Competition Protection Commission, Department of Transport, Department of Foreign Affairs, Commission for Aviation Regulation. The working group should undertake a review of the impact of the COVID‐19 on the aviation/travel sector and issue recommendations for an improved and most importantly sustainable response to future pandemics, which can only serve to bolster confidence in aviation and travel.

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Irish Travel Agents Association submission to the Aviation Recovery Taskforce 16 June 2020 5 Ireland West Airport Task Force r ecommendations -short term

 A clearly time defined roadmap for the lifting of all travel restrictions and quarantine requirements on an urgent basis from the Government, to enable the restarting of the aviation, business and tourism sectors, and provide critical air connectivity to international markets for the west and north west of Ireland.

 The provision of significant financial supports through the creation of an Aviation Recovery Support Fund targeted at the main airline carriers to assist and incentivise them to restore airline capacity to 2019 levels through Ireland’s airports and in particular to the regional airport’s on the western seaboard that are most impacted by this collapse in air travel. The initial scale is estimated to be in the region of €300 million. This can be achieved through a significant reduction in Irish airport charges that will sub vent airline’s losses during the post covid period (18 months +) and be tied into both a restoration of passenger traffic to 2019 levels by 2021, following by an annual passenger traffic growth commitment (+5-10% p.a) through all of the Irish airports to 2024. (State owned and regionals).

 In addition to this a major coordinated international marketing campaign will be required over the next 2 years with significant funding requirements to win back the confidence of international visitors from key European markets, in particular GB and also the US. This programme would be managed through Tourism Ireland’s extensive international office network and focus on partnering with airlines and airports in driving inbound tourism numbers onto the island of Ireland.

 Employment supports are vital for the road to recovery for businesses including aviation, tourism and hospitality, which have been devastated by the COVID 19 crisis. Aviation plays a key role in Ireland’s economic recovery and will require continued support to do so with extension of the Temporary COVID 19 Wage Subsidy Scheme to the at a minimum the end of 2020. We propose that its continuation is aligned with the recovery of the aviation sector to have a meaningful impact on the preservation of employment levels across the industry.

Ireland West Airport Task Force recommendations -medium term

 The continuation of the current Regional Airport’s Programme (RAP) for the period 2020 to 2024 which supports investment in Capital and Operational expenditure of an economic nature at regional airports. As part of this continued support the continuation of support under the Public Policy Remit programmes PPR-O and PPR-C is also recommended. These programmes provide funding investment for critical safely and security capex at Ireland’s regional airports and also provide a % contribution of the funding support towards the airport’s core operating costs relating to fire, security and air traffic control.

 An urgent review of Ireland’s existing National Aviation Policy in the context of the new covid impacted aviation environment, with a key focus on the significant challenges now faced by all Irish airport’s outside the capital city, given the crisis being experienced by all major European and global carriers to provide commercially viable air services to these secondary and regional airports into the future. Policy areas focussed on positive discrimination in incentivising and supporting air carriers to provide enhanced regional connectivity which will be critical to support the economic recovery on a balanced regional basis should be put in place. In addition the funding of key international hub PSO’s (Knock -Heathrow/Paris, Shannon-Amsterdam/Frankfurt) where other air services cannot not be provided on a fully commercial basis should be to the fore in providing key regional connectivity for tourism and economic recovery.

Submission to the Tourism Recovery Group

Also forwarded to, and relevant to, the Aviation Recovery Task Force

Joe Gill – Goodbody

Introduction

This Submission to the members of the Tourism Recovery Group relates to the unique importance of air access to the Irish tourism industry and the overall economy. It details how growth in air access caused the growth in recovery in tourism after the financial crisis of 2008/2009 and how clear and decisive policies adopted now in relation to promoting air access can ensure a rapid and effective recovery for the tourism industry in Ireland.

Air Access and Tourism

There is a strong correlation between growth in air access and international visitor numbers to Ireland. Over 90% of visitors to Ireland travel by air and given the very high load factor (percentage of seats sold) of flights which operate into the country’s airports it is impossible to increase international tourism numbers unless we have increased capacity.

This proven correlation has often been ignored in the past when setting tourism and aviation policy. For example increasing marketing expenditure in overseas markets is wasteful if there is not sufficient air access. Equally, increasing the cost of air travel, as happened with the introduction of an air travel tax in 2009, will automatically result in a reduction in air access given the price elasticity of air travel, and a corresponding fall in tourist numbers. In the wake of Covid any policy response must take in to account these facts.

Major changes have taken place in the aviation industry during the last twenty years. Short haul air travel in Europe is now dominated by five larger airline groups, being Air France KLM, Lufthansa (which owns Swissair, Austrian and Brussels Airlines), International Airlines Group (IAG) which owns British Airways , Aer Lingus, Iberia and Vueling, and Ryanair which owns Lauda Air, Malta Air and Buzz in Poland. Together these carriers account for approximately 70% of all intra European air travel. More importantly, in the context of Irish tourism a small number of these (Ryanair and Aer Lingus owner IAG) represent the only prospects for growth in this country in the next 3- 5 years. Other carriers are displaying a clear preference to support their home economies first in the aftermath of Covid while a number of other airlines serving Ireland may not survive at all. It is imperative in this context that policies are deployed which incentivise Aer Lingus and Ryanair to commit capacity towards re-connecting the Irish economy with the international marketplace.

Lessons from the 2008/2009 Crisis

In 2008 the total passenger numbers through Dublin Airport were 23.3m of which 8.6m was to/from the UK, 12.1m was European and 1.8m was transatlantic. In September 2009 the Government introduced an Air Travel Tax of €10 per passenger. As a consequence of this tax and reduced business travel due to the crisis total traffic fell to 20.5m in 2009 and 18.4m in 2010.

During that time Shannon’s traffic declined from 3.6m in 2007 to 1.4m in 2012 while passenger numbers in Cork fell from 3.18m in 20017 to 2.14m in 2014. The number of tourists visiting Ireland at that time declined from 7.7m in 2007 to 5.9m in 2010.

While there was modest growth in passenger numbers in Dublin Airport between 2011 and 2014 when the total reached 21.7m it was not until the Air Travel Tax was removed in April 2014 and subsequent expansion of capacity from 2015 onwards that substantial increases in passenger numbers materialised as follows: - Passengers % Increase (Millions) 2015 25.0 15.0 2016 27.9 11.6 2017 29.6 6.0 2018 31.5 6.4 2019 32.9 4.4

In total between 2014 and 2019 traffic traffic in Dublin grew by 51.6% at a time when global growth in air travel was more subdued. As a result Dublin Airport moved from being the 25th largest airport in Europe in 2010 to number 12 in 2019. Cork Airport grew by 21% from 2.14m passengers in 2014 to 2.59m in 2019 while Shannon increased by 29% from 1.30m in 2019 to 1.67m in 2018. Of the total increase of 12m passengers during this period, 11.2m. or 93% of the increase occurred at Dublin Airport. Between 2013 and 2019 the number of foreign tourists visiting Ireland increased by 3.0m. or 45%.

Further analysis shows the growth by origin/destination at Dublin:- UK + 2.4m Western Europe + 2.8m Southern Europe + 2.7m Eastern Europe + 0.8m Transatlantic + 2.1m Other long haul + 0.4m

It is also instructive to analyse the growth by carrier/region. Ryanair accounted for 5.5m passengers, 49% of the total increase while Transatlantic represented a further 17% (2.14m.) of which 500k was from Canada. The balance of the increase was spread among a long list of airlines mainly to/from European destinations, principally British Airways from London (approx. 400k) and other long haul carriers who grew by circa 400k passengers in aggregate.

Lessons for the current crisis

If we look at the possible sources of growth in air access based on the experience of 2013-2019 I would expect a number of differences. Firstly, the Transatlantic market will take some years to recover for the following reasons:- 1. Consolidation by US and Canadian carriers. 2. Consumer reluctance to travel long haul in The aftermath of Covid 3. Aer Lingus has grown its network in the last 5 years using single aisle aircraft to secondary cities. The scope for much further growth at this time is limited. 4. Uncertain and unpredictable quarantine and access regulations particularly to the U.S.

Indeed, in the case of Shannon there is an additional issue in that a proportion of its pre- Covid transatlantic traffic was operated by US carriers on older aircraft which they have now decided to retire. Consequently there must be considerable doubt that this traffic will ever return, especially as these carriers are prioritising connections to large European conurbations within an overall smaller footprint.

Secondly, while it is possible that the Middle Eastern airlines will eventually resume their previous capacity it may take at least 18 months and there is certainly no scope for growth. Similarly, it is very hard to be optimistic of any growth from long haul markets in Asia and elsewhere.

Our two largest markets, the UK and Europe, offer opportunities but also challenges. With the imminent effect of Brexit it is difficult to be optimistic. However I believe the key inhibiting factor will be cost which will increase (to the consumer) if sterling weakens against the Euro. Capacity has increased substantially between the UK and Dublin over the last 6 years and we will be doing extremely well to be back to the 2019 activity by the beginning of 2022. I see little scope for capacity increases in this market.

However there are certainly opportunities to link UK airports with Cork, Shannon and Knock. The Irish airports have some links with the UK presently but extra demand could be stimulated with lower fares. Obviously any airline would need to be compensated with lower costs in order to match the opportunities it will forego to continental European destinations from the UK by allocating capacity to routes to Ireland.

With appropriate price stimulation it should be possible to increase passenger numbers on these routes by 600k by the middle of 2022.

Continental Europe offers the greatest potential for growth for both Dublin and the regional airports.

In Dublin there is potential in Scandinavia where both capital cities and provincial cities are underserved and unserved respectively.

Elsewhere many provincial cities in Germany, Poland, Spain and Italy remain unserved or underserved and if demand is stimulated by low fares, offer considerable potential.

Finally there is scope to link some European capital cities with the regional Irish airports. Some of these routes have not worked in the past but I’m convinced with appropriate low fare stimulation of demand underpinned by low costs that these routes can be viable and sustainable.

What needs to be done

In the immediate aftermath of Covid and its impact on tourism, particularly international tourism, it is evident that competition from other countries for tourists will be more intense than ever. We have already seen European governments provide substantial aid to their “national airlines” and hotels, theme parks, resorts and other providers have reduced prices and extended discounted offers in an attempt to jumpstart demand from a smaller cohort of prospective customers. With the reduction in capacity of airlines in Europe and softer demand airports and tourist authorities will be offering substantial incentives to airlines to maintain routes and if possible, increase capacity.

To ensure airlines deploy aircraft in Ireland to operate critical routes as recovery efforts step up the Government must incentivise carriers to re-commence and extend services, especially if demand is tepid and fares are subdued for a period of time.

To this end a suspension of airport fees in exchange for guaranteed daily and weekly services is a fair and efficient measure. It will reward any airline that chooses to operate from Irish airports and that policy can be extended until the economy reverts to normality, probably in early 2022.

Aeronautical charges at Irish airports are about 350m euros annually. Offering free landing charges for a period of up to 18 month, and supporting the airports to fund that, should cost no more than 150m euros. Relative to the scale of support being deployed in other states less dependent on aviation, and compared to supports likely in other parts of the Irish economy, this is a modest sum. Yet it could help secure critical aircraft capacity deployment in Irish airports that help re-boot the overall economy. It is also fair because it can be made available to any airline that takes up the offer. I expect many international airlines will have limited interest in prioritising Ireland given the crises in their own business models and home economies. We must hope instead that at a minimum Aer Lingus and Ryanair respond favourably to such an incentive in the short term with some long haul carriers following suit.

This is a small state investment when one considers the extra revenue accruing from each visitor (average €500) together with the employment creation potential in the region’s tourism industry. At €500 of expenditure (excluding the cost of travel) the VAT revenue alone which accrues to the Exchequer more than makes up for the inventives required to fund the fare stimulation necessary to create the demand on these new routes and to return capacity on existing routes in this time of weak and soft consumer demand.

As most of airport costs are fixed and will not reduce if routes are not flown there is no incremental cost which needs to be recouped. Indeed the extra passengers will generate revenue for the airport when they purchase food and other items at the airport. I believe the issue of state aid is addressed if we make these discounts available to every airline that opens new routes or maintains a certain percent of its 2019 capacity on existing routes.

Summary

Uniquely in Europe, Ireland as a physical island depends most heavily on air access for its international tourists and international trade. Employment, in both the capital and regions, is heavily dependent on air services. While other countries have core road and rail infrastructure connecting their economies with the outside world Ireland is uniquely dependent on commercial air travel infrastructure.

In a competitive environment where other regions/countries will be offering incentives it is important to remember that airlines have suffered enormously in this crisis and will have to seek out the most profitable opportunities to ensure their solvency and sustainability.

Effectively, an airline can decide to carry passengers using its expensive and mobile aircraft assets to a variety of destinations and in the current environment will be unable to accommodate all the offers it receives for its business.

I firmly believe that if we have a clear focus on the cost variables that dictate where aircraft are deployed, and equip airports financially to provide support, a rapid and early move can secure commitments for the second half of 2020, 2021 and thereafter which underpins the return of our tourism industry and overall economy to growth and prosperity. A clear and effective suspension of airport fees during this emergency action plan is the optimal tool to utilise in response to this unprecedented crisis.

Kerry Airport PLC Submission to the Department of Transport, Tourism & Sport – Taskforce for Aviation Recovery 15th June 2020

TASKFORCE FOR AVIATION RECOVERY

15th June 2020

Introduction

Chairperson and Members of the Taskforce for Aviation Recovery,

Thank you for this opportunity to contribute this submission to the taskforce for your consideration. It is important that the regional airports have a voice with regard to any decision making, and also represent their colleagues in tourism and Industry. So many who are dependent in rural Ireland on reliable air connectivity have also endured the impact of COVID-19 on their businesses and livelihoods. We fully understand the critically short timeline for this taskforce and the need for haste to ensure we can all contribute to salvage what is left of 2020 and secure a real and absolute recovery in the coming months and years. For this reason we will keep our submission brief. The persistent theme that remains from our customers and partners is the need for clarity and definitive timelines to return normal air travel rather than the continued incongruence between airlines, tour operators and the messaging from government and public health.

Immediate Action

In terms of immediate action the first priority, we believe, is to publically support the opening up of airline route maps for the return of passenger travel. Others in the Eurozone and further afield with similar ‘R’ numbers have begun to open up their borders to business and tourism. The available evidence demonstrates there are no confirmed cases in Ireland directly associated with transmission on a plane or in an airport. The 14 day rule is a recommendation rather than a ‘must’ and as such people who are asymptomatic have and will continue to ignore it whilst responsibly adhering to the general public health guidelines regarding social distancing, hand hygiene and respiratory etiquette.

The message needs to be the same for the travelling public as it is for the general population, isolate if symptomatic, wash your hands, use a face covering when on public transport or unable to maintain a 2 meter physical distance but yes travel to these destinations because the ‘R’ number demonstrates the risk of exposure with good practices remains the same there as it does here. Unfortunately the inaccurate and widely accepted fear is that air travel itself is a risk rather than the true risk being nonconformity with physical distancing and other public health guidelines.

Short Term Action

In the shorter term it would be very helpful to get a positive announcement regarding RAP Regional Airports Programme which would support us in re-establishing our path to growth and sustainability in the future. We can all understand that this journey has been given a significant blow and set us back

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15th June 2020 perhaps several years however we still believe that with the support of the RAP we can continue to contribute so much more than we receive to our rural economies and the greater national purse.

A positive announcement on CAPEX 2020 would allow us to commence necessary upgrades including new screening systems that will shorten queuing times at security enabling us to better manage our new physically distant environments.

An expedited timeline to OPEX payments would help significantly in surviving the present loss enduring reality, we stayed open to support COVID-19 emergency planning, and critical journeys etc. during the past months which benefited the region on many occasions. It should also not go unstated that the Board of Directors and staff of Kerry Airport, the people of Kerry and further afield will always be grateful indeed that the Dublin flights continued throughout the pandemic and are a great support to us here when situated so distant from the capital. The loses in 2020 at Kerry Airport and with no doubt every other airport in the nation are substantial and if this and the fact we stayed open whilst not benefiting in any way from COVID-19 wage supplements could be recognised with higher enhanced it would go a long way towards aiding our recovery and saving employment.

Longer Term Action

In the not too distant past we presented a brief ‘Blue Sky’ business development plan to Minister Shane Ross TD which incorporated increasing the size of the terminal/hangar space here to enable us elevate capacity, attract new routes into the region and new services into our business. The advantages from this development to the region would include increased traffic both tourist and business and the associated uplift to this rural economy along with new employment both in the short and long term. Other longer term issues include;

• Discussions of VAT to be charged on Aviation Fuel to be avoided

• Re-introduction of Air Travel Tax should be discouraged

• Importance of PSO renewal process in mid-2021 is paramount now and should begin sooner.

Finally, thank you again for this opportunity to contribute, I wish the Taskforce all speed and success in their endeavours and I remain confident that the decisions that are made will benefit all fairly and equitably. In a county where over 20% of our population are directly employed in tourism and where businesses choose to locate in some significant part because of air connectivity your decisions and recommendations to government are paramount.

John Mulhern Chief Executive Officer Kerry Airport PLC

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Submission to the Task Force for Aviation recovery from Lufthansa

1. What are the short term actions needed? What is urgent and important right here and now?

· Immediate reduction in Clare Co Council Rates to a nominal sum for the next three years (2020 – 2022, Eur 500 to 600K pa for LTSL)

· Immediate reduction of the Ground Rent payable to the Shannon Airport Authority for the next three years (2020 to 2022, Eur 250k, to 300k pa for LTSL)

2. What is needed for the medium term, 3-6 months?

· Continuation of the TWSS at least up until the end of the 2020 or until our Business Volume returns to a normal level (could be 12 months).

3. What do we need over the next 2-3 years?

· Remove the requirement to recruit aviation trainees from the Live Register

· Enable trainees to receive the government subsistence support during their training period when they don’t come from the live register

· Make sure Shannon Airport stays open (seems an obvious statement but we can’t operate if aircraft can’t land and take-off)

Proposed recommendations for an Aviation Recovery Plan - Padraig O Ceidigh Date: 16th June 2020

Principal recommendations - summary:

Overall purpose of the task force is to advise The Minister and his Department on the framework for promoting the return of aviation connectivity and aviation enterprises that are critical to supporting the wider economic recovery as quickly and orderly as possible taking public health as a key underlying factor.

The Aviation industry together with the Irish Aviation Authority have at all times and continue to put passenger safety at the forefront of everything they do.

We are very fortunate in Ireland to have some of the best and most successful airlines and airports in the world, as well as having the largest aircraft leasing industry of any country.

The industry will change fundamentally from a passenger, airport and airline perspective. This will create significant knock on operational and economic consequences.

We, as a State, have to support this vital industry to, initially survive and, then transition again into a world class provider of air services.

The primary purpose is to reintroduce both trust and confidence in the industry as soon as possible and, to facilitate the industry transition back to its pre Covid situation.

It is impossible for any industry to survive a sudden and unexpected drop in excess of 80% in its business. This is particularly severe for the aviation industry with its very high fixed costs, low margins and, at the same time all of its income being variable which is volatile and fundamentally aﬀected by global factors.

Liquidity is a major stressor for the industry and required to be addressed immediately.

Operational issues will / are coming to the fore. For example, pilot and crew mandatory recurring training (in order to keep their licences current) will soon become a major operational and HR issue for all airlines and also for many airports. Aircraft, when taken out of active service have to be transition to a diﬀerent maintenance program and, then transitioned back again to recommence operations. Costs are increasing while, at the same time, income has practically disappeared. A similar situation exists for airports who also operate to the highest regulatory requirements.

There is also a clear need for a co ordinated member State approach to reopening the air travel industry. Eurocontrol in their report of the 11th June indicated that the number of EU flights are at 20% of their 2019 level for this time of year.

The main highlights to their report are: • Trend illustrates a pick up towards the end of June • Chinese domestic now at 88% of 2019 levels, however International travel remains low • North America planning a resumption of services on the North Atlantic to approximately 35% of normal capacity over the coming weeks

• New quarantine procedures introduced in UK and Ireland is eﬀectively preventing operations planning for July, at the earliest to and from those States

Outline of key proposals:

1. Short term - proposals for survival of industry • Follow EASA / ECDC / DTTAS Covid 19 guidelines including guidance on quarantine. • Facilitate and support an increase in flight operations with a moratorium on airport charges and related taxes (such as airport rates) in order to minimise liquidity challenges for both airlines and airports. • A State Aviation Recovery Support Fund is urgently required to support industry in both the short and medium term

2. Medium Term - transition period - three months to 1 year • Purpose is to facility the industry to create a transition into a stable environment • The State Aviation Recovery Support Fund should continue to support the industry by means of subsidising airport charges to the eﬀect that there are zero charges on airlines for the next 12 months. This will cost the State approximately €300m in year one which would be paid directly to the airports as compensation. This State support would decrease significantly in year’s two and three as airlines would recommence payments • Increase marketing support to Tourism Ireland by 50% from €44m in 2019 gradually to €66m for 2021 • Incentives should be instituted to encourage airlines to provide services from the Regional airports as per Government policy on regionality • The Covid 19 employment support scheme should be maintained for next 2 months • Ensure that existing airports infrastructure are maximised with regards to utilisation in line with international practice (this is necessary for Dublin airport in particular)

3. Long Term - stabilisation period - 1 year to 3 years • Regional airports should be provided with State grants to alleviate existing capex debt on their Balance Sheets and, support essential capex over the coming 3 years. • Airlines should pay 50% of airport charges for year two and 100% charges for year three. However, this derivation from airport fees should be conditional on benefitting airlines operating regional routes to the same level as 2019, and, increasing operations by a minimum of 10% per annum for the following two years. • A special support mechanism should be introduced to support Shannon airport attract and retain Trans Atlantic operators. • Regional International PSO routes should be considered and implemented

Overall - airlines such as Ryanair and Aer Lingus should not be disadvantaged compared with their European counterparts, merely due to their long standing operational and financial prudence, professionalism and success.

Also, Irish and European airlines and airports should be eligible for direct support from the EU funds, such as the EU Coronavirus Response Investment initiative, made available to tackle the economic crisis, as they will be instrumental in ensuring a swift recovery of the European economy at large. EU and national measures should ensure liquidity for airports and airlines via guarantees or credit facilities.

In the final draft version of the code of practice, it details that “Air Carriers, Airport Operators, and certain other service providers are responsible for ensuring implementation of the measures as set out in this Code of Practice, including monitoring implementation and providing feedback, in line with the EASA Charter”.

In addition, in my opinion, the IAA could have a role to:

• Monitor, on behalf of the FAL Committee, that the air carrier and airports operators have the required policy’s, procedures, training etc detailed in the relevant operational and training manuals, including appropriate risk assessments;

• Monitor the Compliance function within each air carrier and airports operators in respect of these CV-19 measures; and

• Conduct limited but targeted observations at airports and on aircraft to validate the compliance data/reports by air carrier and airports operators in respect of these CV-19 measures.

The IAA will require additional resources and support in order to carry out this role.

I am sure that the operators will implement the code in good faith. However, they are still ‘guidance material’ with NO legal standing.

Challenges may arise if/when passengers report ‘non-compliance’ with the guidance.

Since powers of enforcement do not exist within legislation for the body that monitors the implementation of these CV-19 measures (i.e. International, European or National law), I believe that DTTAS should add an appendix to their CV-19 Code of Conduct, outlining their expectations on this ‘monitoring body’. This would give some comfort to that Body, that they will not left exposed when challenges arise and where enforcement of ‘guidance’ becomes difficult.

In my opinion the above recommendation will help to provide comfort and reassurance to passengers, aviation employees and, to health authorities.

AVIATION TASK FORCE PAPER – Wed, 17 th June 2020 Ryanair

Irish air traffic collapsed to almost zero for the first half of Summer 2020. Less than 50% of 2019 capacity has been restored from July 2020.

 The Aviation Task Force should focus exclusively on the restoration of airline capacity at Irish airports to 2019 levels since other key issues are addressed by other agencies/task forces, e.g. ̶ NCADF, National Facilitation Committee, IAA & EASA on operational issues ̶ Tourism Task Force, Tourism Ireland & Failte Ireland on tourism issues ̶ ECDC & NPHET on health issues

 Irish airports will be competing for scarce airline capacity against well-funded countries/regions.  Without restored airline capacity all other customer and tourism initiatives are futile.  Most analysts predict that European capacity will not return to 2019 levels before 2023.  All of the top four airline groups, with the exception of Ryanair, have signalled capacity cuts for the next two years, including Lufthansa’s grounding of up to 50% of its fleet.

Short Term - “Save the Summer” Ryanair and Aer Lingus account for c.80% of all Irish capacity and over 90% of Irish short haul capacity (which has a greater chance of immediate stimulus).  Ryanair has restored 50% of 2019 Ireland capacity from July and ordinarily requires a minimum three months’ lead time to sell additional capacity.  Additional flights can be achieved from September, but only if on sale at the end of June.  Immediate Airport Cost reductions and Quarantine removal are necessary for additional summer flights.

Medium Term – “Secure the Future” Ireland will face intense competition from well-funded touristic and business competitors over the next five years, who will compete more vigorously than ever for scarce airline capacity. Easyjet confirmed that they will operate a smaller fleet in 2021, Lufthansa announced the disposal of 100 of their 700 aircraft, along with the grounding of half of their fleet. Condor, TUI, Alitalia and others announced significant fleet cuts and job losses. European airports of all types will compete to replace this lost capacity.

The restoration/addition of routes and seats to Irish airports will require lower airport costs and low cost certainty for the next five years to secure scarce airline seat capacity for Ireland. Any threat of additional costs (ATT, Green tax, etc.) will redirect capacity from Ireland as ATT has demonstrated previously.

TRAFFIC & ROUTE RESTORATION

A transparent system of airport cost reductions/incentives is required to urgently restore traffic to 2019 levels:

 Zero Dublin Airport charges to December 31 st 2020.  €15 per arriving passenger incentive to December 31st 2023 at all ROI airports, applicable to all arriving passengers above 50% 2019 monthly level by airline, conditional on 1m annual arriving passengers by individual airline at regional ROI airports from 2020.  ATT abolition and guaranteed no “Green Tax” to, earliest, December 2025.  Any increase in the Dublin price cap 2020 – 24 due C19 to be funded by the owner of the DAA.  Note: Total ROI traffic in calendar 2019 was c.36m (18m arriving) passengers. The max cost of the scheme would therefore be a modest c.€135m per annum.  On the basis that 50% of arrivals are visitors, the value to Ireland of restoring traffic from 50% to 100% 2019 levels is €4.5bn p.a. for a €135m investment (9m visitor arrivals x €500 spent).  ACI reports that 750 airport jobs (and more in the wider economy) are delivered by every 1,000,000 air passengers. 2019 air traffic supported over 27,000 airport jobs.

SHANNON GROUP

Background:

Shannon Group is the beating heart of economic prosperity in the Mid-West and located in a pivotal position within Ireland’s Atlantic corridor.

At its core is Shannon Airport, whose success is critical for the economic wellbeing of businesses which rely on its air services. These regions have been amongst the worst affected by the COVID-19 crisis given their heavy reliance on tourism and the hospitality industry.

As an island economy built largely on international trade and foreign direct investment, aviation is the lifeline that connects us to the global economy.

The pandemic has had a catastrophic impact on aviation, shutting down Shannon Airport to scheduled passenger traffic, with traffic expected to be down by circa 70% this year, and economic forecasts predicting that air services will not get back to 2019 levels for at least three years (2023). The virus has resulted in the closing of international and domestic business and tourism travel, shuttering the region’s hotels, restaurants, bars and guesthouses.

The monumental economic and social fall-out from the virus has shown the critical importance of delivering balanced regional development. There is now an urgent need to accelerate and immediately implement the Government’s Project Ireland 2040 plans to deliver balanced regional growth in regions outside of Dublin. If we have learnt anything from this crisis, it is that we need strong regions to avoid over reliance on the east coast and an over concentration of industry and population in one part of the country. All parts of Ireland must thrive if we are to prosper as a country.

The ability of the region to rebuild in the aftermath of this pandemic is reliant on having a strong and resilient airport. Shannon Airport is a vital national strategic interest, that plays an essential part in bringing business, tourists and cargo to the region.

 Over 40% of US FDI companies are within the airport’s catchment area reflecting its importance as a key FDI enabler for Ireland. The re- introduction of UK, European and transatlantic flights is critical to enable business and tourism industries to recover from this crisis. The most recent analysis of FDI job announcements in the Mid-West Region indicated that every one of the companies involved cited Shannon Airport as a factor in their investment decision.

 Shannon Airport directly generates close to €1 billion in GVA for the Irish economy each year, contributes €318 million annually in tax revenue to the Exchequer and supports 13,695 jobs through its activities.

 In addition, Shannon Airport has an important catalytic impact on both FDI and Tourism:

It supports the FDI sector with an economic impact of €2.2 billion annually, supporting 21,000 jobs and contributing €687 million in tax revenue.

The Airport supports the tourism and hospitality sectors with an economic impact of €430 million every year in GVA, supporting 10,900 jobs and generating €137 million in tax revenue.

The recession caused by the pandemic, leading to extensive job losses in the Mid-West Region and along the Atlantic Corridor, highlights the National Strategic requirement for a strong Shannon Airport.

The regions now also face the imminent impact of Brexit in January 2021 and the uncertainty that exists regarding Britain’s future relationship with the EU and the additional impact this will have on Ireland’s economy.

The National Development Plan, Ireland 2040 acknowledges the key role that ‘High-Quality International Connectivity’ plays in the nation’s wellbeing. “As an island, continued investment in our port and airport connections to the UK, the EU and the rest of the world, is integral to underpinning international competitiveness. It is also central to responding to the challenges as well as the opportunities arising from Brexit,” the plan says.

Further the plan says ‘Investing in Regional Growth’ must be a priority. “Future employment growth will require a major focus on boosting regional growth potential to secure sustainable quality employment. This necessitates the generation of growth that is sustainable, driven by exports and underpinned by innovation and competitiveness in all regions,”..

The National Aviation Policy for Ireland 2015 states that Shannon Airport holds a strategic importance for connectivity of the Mid-West region and is vital as a key tourism and business gateway for the region, particularly with regard to the development of niche markets and must be supported.

Shannon Airport is the very lifeblood of the region. The air services provided through it are an essential artery for Irish and international businesses located here, and its location at the heart of the Wild Atlantic Way make it an important gateway for international visitors. Strong regions and regional cities make for a strong national economy.

THE GOVERNMENT SUPPORT PACKAGE REQUIRED TO KICK- START ECONOMIC RECOVERY AND SUPPORT THE DELIVERY OF BALANCED REGIONAL DEVELOPMENT

Immediate actions/ supports required to deal with the catastrophic fallout from this pandemic:

 A clear roadmap for the lifting of travel restrictions and the removal of the quarantine provisions in line with the EU.

 The provision by Government of significant and effective funding to assist Airports restore air services providing vital air connectivity necessary to support business and tourism. While this funding would go directly to supporting our main airlines to subvent losses in the post Covid recovery period it must be conditional on airlines reintroducing 2019 level of services in each of the country’s airports by 2021 and a commitment on minimum growth of 5% p.a. in each of the airports until 2024. This is an opportunity for Government to demonstrate its commitment to and support for its stated objectives in the Project Ireland 2040 plan for balanced regional development by ensuring the delivery of air services directly into the regions to stimulate jobs and economic growth

 Waiver from commercial rates for Shannon Airport for two years.

 Continuation of the Wage Subsidy Scheme for the aviation and tourism sectors severely impacted by the pandemic until at least March 2021.

 Funding to complete essential safety and security capital expenditure projects which do not create any commercial return and currently must be funded by Shannon Airport from its own resources which are drastically depleted as a result of this crisis.

 Trends in market share clearly highlight the need for a more targeted regional focus. The decline in the market share of airports located in the regions reflect the dominance of Dublin. These trends pose serious concerns not only from a tourism perspective but also for general economic growth in the regions. Further declines in market share will have serious negative implications for economic development, given the known correlation between tourism and FDI growth and airport connectivity. A regionally targeted marketing support scheme will ensure that the excess capacity that is available in airports outside of Dublin is utilised to the fullest extent possible.

 Shannon Airport requires improved ground transport from Shannon to Galway and urgently needs the NTA to look at sanctioning licences to private bus operator on this route.

Changes sought to National Aviation Policy:

 Acceleration of the delivery of balanced regional development by redirecting opportunities into the region. Shannon Airport with passenger numbers under 3 million (and therefore eligible for capital support without EU State approval) can deliver on the objectives of Project Ireland 2040, to enable the cities and towns in the Mid-West and beyond to grow and to enhance their significant potential and make the region a thriving, attractive place to live and to work and into which businesses will invest.

 In developing the Regional Airports Programme 2020-2024 consideration must be given to the aviation landscape holistically. Given the spare capacity available in airports in the country, particularly at Shannon Airport, it is opportune to consider the environmental impact of promoting excess capacity in Dublin and instead look at ways to encourage air transport users to look to the airports in their region. In recent years many overseas visitors wishing to holiday on the Wild Atlantic Way are accessing Ireland through Dublin when Shannon Airport lies at the heart of the Wild Atlantic Way. Flying directly to an airport located within the region reduces their overall carbon footprint in Ireland, will improve the overall visitor experience and in turn grow the overall visitor numbers into the country

 The designation by Government of Shannon Airport as Ireland’s dedicated location for commercial transit operations. This designation would be an opportunity to alleviate pressure on Dublin, freeing up valuable slots without requiring costly infrastructure investments. By moving services such as transit and air cargo to Shannon which has ample capacity and facilities such as US Preclearance, it would assist in balancing the disparity between Irelands main airport and those in the regions.

 Airline connectivity from Shannon to key hubs in the UK , US and Europe is vital to support business and tourism and in particular to recover in the aftermath of this global pandemic and therefore consideration should be given to establishing a PSO to a major European Hub to support the retention and expansion of companies in the Mid-West and provide additional employment for this region.

 Access to funding to develop additional hangars to support the expansion of the aviation MRO industry in Ireland.

 In line with the National Aviation Policy to incentivise and support the designation and development of Shannon Airport as Ireland’s international air-cargo hub with cold chain facilities.

We, in Shannon Group urgently need the incoming Government to implement the measures set out in this document to not alone alleviate the financial burden on the Group and provide assistance, most particularly in the Airport but to safeguard this vital infrastructure for the business and tourism sectors in the Mid-West and the Atlantic Corridor who rely heavily on its success. We believe that implementing these recommendations is an opportunity to deliver on the commitments and assurances given under Project Ireland 2040.

A: 1 Northwood Avenue, Santry, Dublin D09 V2F7 T: +353 1 844 7700 F: +353 1 844 7701 E: [email protected] www.stobartair.com 15stJune 2020

Taskforce for Aviation Recovery c/o Ross Keane Air Navigation Services Division Department of Transport, Tourism and Sport Leeson Lane Dublin 2

RE: Invitation for Written Submissions to the Taskforce for Aviation Recovery

Dear Members of the Taskforce for Aviation Recovery,

I wish to thank you for your request for input from Stobart Air on the actions needed to support the recovery of the Irish aviation industry.

As Ireland’s largest regional airline, Stobart Air have been a key part of the Irish aviation industry for over four decades, connecting regional communities, people and businesses across the nation with our capital city and with our main trading partners in the United Kingdom. Stobart Air’s network of routes encompasses five Irish airports including Dublin, Cork, Shannon, Kerry and Donegal along with a wide coverage of regional cities in the United Kingdom. Our route network covers 23 routes and 17 airports with Stobart Air accounting for 49% of all flights between Ireland and regional cities in the United Kingdom outside of London.

A collaborative and coordinated approach by industry, government and relevant stakeholders is vital to reconnect Ireland with our trading partners across the globe.

Immediate actions required:

A wide range of policies should be explored for in the immediate term to help re-start aviation following the catastrophic impact of COVID-19:

The aviation and wider tourism industry require urgent clarity on how long quarantine of International arrivals will remain in place. Airlines require an update from the Department of Foreign Affairs on travel advisories for specific countries in line with the recommendation from the European Commission that Member States remove such restrictions by 15 June to enable citizens to travel again. Suspension of all existing published aeronautical and air passenger charges at Ireland’s state airports replicating measure in place in Norway. Temporary extension of payment terms for airport charge invoices at all other airports in Ireland until 31 October 2020 replicating measures currently in place in Sweden and the Netherlands. Immediate deferral of en-route and terminal ANSP navigation charges for a period of up to 12 months to enhance liquidity and assist the airspace users during the recovery phase.

Stobart Air UC Directors: W Brady, A Jolly, J Brown Registered Office: 1 Northwood Avenue, Santry, Dublin D09 V2F7, Ireland Registered No. 28858

A: 1 Northwood Avenue, Santry, Dublin D09 V2F7 T: +353 1 844 7700 F: +353 1 844 7701 E: [email protected] www.stobartair.com

State support in line with 2019 revenue contributions. Embrace the relaxed EU fiscal rules in the Coronavirus Response Investment Initiative Expand initiatives such as the Restart Grant offered by the Department of Business, Enterprise, and Innovation to airlines Extend the Debt Management measures that were put in place by Revenue for SMEs to be extended to airlines Relaxation of the financial tests / criteria that need to be satisfied to qualify for financial support under the Pandemic Stabilisation and Recovery Fund (PSRF). The PSFR is intended to support "Enterprises that were commercially viable prior to the COVID-19 pandemic and can return to viability and contribute to the Irish economy". Applying 'normal short term' commercial tests to businesses in the aviation sector does not seem to be in the spirit of what is intended as the recovery in the industry will potentially be much slower. Extension of capital grants from the Department of Business, Enterprise and Innovation to airlines and aviation providers for the retrofit of workplaces such as aircraft maintenance facilities. Re-examination of the EC Guidance of passenger rights pertaining to refunds rather than vouchers

Medium term actions required:

Within the next 3-6 months it is expected that airlines will recommence services in line with government guidelines. The road to recovery will however be a long, drawn-out process and regaining trust of the traveller will be integral to the speed of recovery. Actions which should be explored include:

Commitment from government on a further extension of the wage subsidy scheme until April 2021 for industries most impacted by COVID-19 with the aviation and tourism industries being most impacted. Detailed plan from the Commission for Aviation Regulation on the re-evaluation of published charges at Ireland’s state airports for 2021. In recognition of the severe and unprecedented crisis in the aviation industry, there is a requirement for the continuation of slot use alleviation through the upcoming Northern Winter 2020/21 and Summer 2021 seasons at all slot-coordinated and schedule facilitated airports. Relaxation of rules pertaining to marketing support from Tourism Ireland. Removal of the need for match funding from the airline in a joint marketing campaign.

Long term actions required:

Longer term it is important that there is a sustainable recovery of the air transport sector. Investment will be needed to expand connectivity. The development of new clean technology is needed as the transport sector is vital to relaunching both the National and European economy. To this end the below actions should be explored:

Stobart Air UC Directors: W Brady, A Jolly, J Brown Registered Office: 1 Northwood Avenue, Santry, Dublin D09 V2F7, Ireland Registered No. 28858

A: 1 Northwood Avenue, Santry, Dublin D09 V2F7 T: +353 1 844 7700 F: +353 1 844 7701 E: [email protected] www.stobartair.com Deferral of CORSIA until 2024 with 2023 being the baseline. Any application of this scheme prior to that would impose an inappropriate economic burden on international aviation at a time when demand will remain supressed.

Examination of a European wide approach to managing such pandemic situations in the future. We need harmonisation in application of policies across Member States to ensure cross-border commonality and the removal operational complexities. Investment from government for the development and production of sustainable aviation fuels not only helping Ireland achieve its carbon reduction targets but also helping in the development of indigenous industry. Commitment from government that no Aviation Travel Tax will be introduced in any forthcoming budget.

Stobart Air welcome the establishment of this Task Force for Aviation Recovery, to provide practical, aligned guidance to government in order to restart the aviation sector and recover from the impacts of COVID-19 in a coordinated manner.

I appreciate you taking the time to review our proposed actions and remain at your disposal should you wish to discuss this matter further.

Sincerely

Andy Jolly Managing Director, Stobart Air

Stobart Air UC Directors: W Brady, A Jolly, J Brown Registered Office: 1 Northwood Avenue, Santry, Dublin D09 V2F7, Ireland Registered No. 28858

Mr Ronan Keane Air Navigation Services Department of Transport, Tourism and Sport Leeson Lane D02TR60

18 June 2020

SWISSPORT RESPONSE TO AVIATION RECOVERY TASKFORCE SUMMARY INFORMATION PAPER 12 JUNE 2020

Dear Ronan,

Thank you for extending the invitation to Swissport to respond to questions outlined in the Taskforce’s Summary Information Paper. We are particularly grateful.

While not all sections and question are directly relevant, there are a number of general points and themes that we would like to formally make under relevant headings outlined in the paper.

Suggested Recovery Issues – Strategic Connectivity

Swissport maintains significant operations with over 800 staff operating at Dublin, Shannon and Cork Airports. We offer a range of services to airlines at all three locations including ground handling, aircraft fuelling, baggage handling and air freight. Regardless of the support from stakeholders such as the major airlines and airports, without ground handlers, Ireland’s skies will remain empty.

Our business model is built and operates on the principal of volume and usage. Therefore, when airlines are not operating, we do not get paid. As we offer services at all three main airports, we are able to scale the support we can offer to airlines who wish to operate routes at those venues. This would also be the case if routes/services were ‘temporarily reallocated’ to distribute the load between airports.

Suggested Recovery Issues – Restoring Consumer Confidence

Swissport wholeheartedly agrees that the return of consumer confidence in a safe manner is the top priority for all stakeholders in the industry.

We believe that the Irish Government should put agreements in place to create ‘air corridors/air bridges’ between countries with similar risk profiles to ensure that access is available in and out of the Island. This would also provide the Irish economy with an avenue for recovery for the aviation and tourism industries.

Air corridors will promote increased travel between countries immediately and the promotion of air travel is fundamental to the long-term industry solution for airlines, airports, handling companies, leasing companies and maintenance and repair operators. It will have the added

benefit of reducing Government subsidies in the form of the Pandemic Unemployment Payment and the Temporary Wage Subsidy Schemes.

Swissport recognises that any and all action taken to encourage consumer confidence must not create further risks to air passengers, residents of the State and the Irish health system.

Therefore, we suggest the creation of a mechanism that allows for the removal of the 14-day quarantine and restrictions on people travelling into/out of Ireland. This could take the form a medical clearance, where a certified ‘Medical Visa’ or ‘Medical Passport’, would allow people to freely travel in/out of the Ireland without quarantine.

By creating a speedy and efficient testing regime, the Government can protect public health, help to restore public confidence and aid the resumption of the aviation industry.

If passengers are mandated to get tested before they depart on a flight or after they arrive from a flight, and they comply with all of the necessary contract tracing requirements, it would create a safe mechanism for passengers to come into the country without exposing the Irish public to a greater risk of COVID.

This would involve setting up a medical centre at each Irish airport to test inbound and outbound passengers. Passengers would pay for the tests either through an airline surcharge applied at the time of booking or via direct payment for those passengers with pre-existing bookings.

The advantage of setting up a system of medical screening at Irish Airports is that it would allow aviation to operate while providing the necessary reassurances to public health. Moreover, it could allow the gradual return of tourism where Ireland is positioned as a safer destination than other destinations.

Please see the attached presentation as an appendix. Swissport, together with its partner Collinson, hope to have a trial of this service, using PCR testing in place and operational at Heathrow Airport within the next fortnight. Swissport is happy to share all our learnings from that trial as soon as possible.

In terms of the recovery measures and national policy supports that have been put in place, Swissport wants to acknowledge the range of efforts and the speed of implementation by the Irish Government. It has listened to concerns and moved quickly to implement a number of measures including the Temporary Wage Subsidy Scheme, Essential Service Designation, a reduction in PRSI, local business rate waiver and an extension of security clearances. This has not been our experiences in other jurisdictions.

It is reassuring that the Government has indicated that the TWSS will continue into the future and we are keen to understand the duration and level of support that will remain in place. Hopefully that will be forthcoming in the near future and it will provide greater flexibility to allow Swissport and other companies to match the return of employees with a return of services. This will help to minimise the level of redundancies in our sector.

As we have articulated in previous correspondence, this is quite simply the biggest crisis ever faced by our industry. We appreciate the commitment of the Irish Government to urgent action by creating this task force. It is now imperative that it produces real and actionable recommendations and I have every belief that it will.

Yours sincerely,

Jason Holt Chief Executive, Western Europe Swissport [email protected]

Cc: Anthony Tully Director Ground Handling Operations Swissport Ireland Cargo Terminal 2 Dublin Airport [email protected]

Safely Re-Opening Britain’s Borders.

Proposed solution to easing the travel quarantine while maintaining positive public perception and traveller safety.

11th June 2020 Current Situation

THE QUARANTINE

• From June 8th, the Government has imposed a 14-day quarantine on travellers arriving from abroad • This position has faced criticism from the travel and leisure industries as well as business leaders • Collinson and Swissport believe that there is a viable and science-led alternative that can be a natural next step to allow the government to ease the quarantine while maintaining public confidence

2 Why has the quarantine been introduced?

‘Following the Science’ Public Perception & Confidence • As caseloads of COVID-19 decrease, we can move • The British public has demonstrated resolve in (back) to contact tracing following close to 3 months of lockdown • This is a great step forward but depends on case • After personal sacrifices by many, there is resistance numbers being & remaining small to any measures that could be perceived to allow the • Several approaches to identifying virally infected virus to come into the country from abroad passengers have been tried in the past, but none • Other countries such as Singapore have experienced deemed effective: additional spikes after initially relaxing their border ͯ Temperature checks restrictions HOWEVER ͯ Passenger questionnaire • Given this, there are only two further options if • Many are seeking a return to a ‘new normal’ travellers are to be allowed to enter the UK: • Many are seeking to understand if they will be able to take a summer holiday abroad this year ✓ Quarantine ✓ Rapid testing soon after arrival • Business leaders are calling on a return to vital business travel (or pre-departure) • The British economy cannot afford a diminished aviation sector shadowed by a rejuvenated government funded competition from Europe 3 ‘Test-To-Travel’ Inbound PCR Testing Enables Easing of Quarantine Restrictions

Leverages Collinson’s PCR testing - reliable Biotech Network of British Critically, quarantine can ‘gold standard’ of virus test centres across the UK + still be maintained for testing Swissport’s global aviation logistics & connectivity those not wishing or able to avail of the test – maintaining public confidence as scheme is rolled out and scaled to Testing centres can be Is good to the NHS by not meet demand. swiftly setup at key using up vital NHS tests or airports resources

This is a solution that at scale has the ability to

The predicted 95%+ of rescue the UK travel Test results are typically passengers who test industry and the key available within 5 hours. negatively can go about their industries associated with Travellers to be notified by business as usual within max it – leisure, sport, culture SMS or email 24 hours of arriving in the UK and business.

4 Supporting the Government Position

Science-Led Public Confidence As many other governments around the world have The quarantine can remain in place for those unwilling done, the UK government has relied on scientists to or unable to avail of it. This is a new option in addition to guide the way to ensure the safest choices are being the quarantine, meaning an easing and not removal of made. the quarantine. This is in fact a natural progression to the current quarantine measures.

This is a science-led approach, led by scientists. Those who wish to avoid the quarantine can take the test, return a negative result and then carry on as By utilising the same reliable tests as currently being normal. used in the health sector, confidence can be had in • Critically, begin reopening inbound tourism – critical their application and accuracy rate. for the recovery of the tourism, leisure, culture and sports sectors • Begin supporting business travel – worth £220 Bn to the UK^ economy • Enable outbound tourism for UK residents

^BTA as it pertains to UK GDP, 2020 5 How it Works: Inbound Proposition

Within 24 hrs

Book Attends appointment Travels to Notification Swabs taken by Appointment accommodation PCR Neg Collinson nursing team, Leave Quarantine facilitated by Swissport quarantine and contact personnel details given

PCR Pos Potential Remain in integration Batch quarantine with NHS / RT-PCR 5 Hours PHE Gold standard Results systems From Lab

Collinson Biotech Network Further Details

LOGISTICS COMMERCIALS • Swissport & Collinson are confident that we can get • Initially, this is a customer-pays model an inbound pilot scheme live at a UK airport within 2 • Airlines may wish to look to include this in premium weeks fares to entice premium passengers back into the air • The proposition can be scaled in line with returning • Equally, this could be displayed in the flight booking demand for air travel path as an additional add-on • Collinson’s Biotech Network consists of labs • Consider Government to fund hardware Capex throughout the UK. Key hubs to be created near to airports allowing for swift transport of swab samples using the same protocols as used in home swab SECURITY & PRIVACY tests by the NHS. • Fraud will be avoided by supervision of nursing & • Laboratory processes are strictly regulated and Swissport staff who will check necessary documents accredited before they become part of the network. • We will seek to work with PHE. Ideally, with traveler • Swissport operates at 23 UK airports & 3 in Ireland permission, results can be shared with PHE and fed into contact tracing exercise

7 Outbound and Air-Bridge Propositions

While the focus for easing the quarantine is on the inbound proposition, a robust outbound and air-bridge proposition also brings benefits.

Outbound Air-Bridge An outbound proposition would see a traveller Airports around the world are in discussions about the obtaining a negative test result within 4 days of travel. establishment of air-bridges connecting airports.

The test can be conducted at an airport, or at ‘in-city’ Should these air-bridges come into play, bilateral locations. agreements on testing could bring ease for the traveller as they would need to test only at either the origin or destination. In order to ensure public safety, travellers on Travellers would be provided with a verified certificate journeys more than 4 days would be required to be that demonstrates that they hold a valid negative test. tested on both ends of their journey, however by implementing air-bridges, only one test per journey is required.

8 Industry Benefits

Benefits for Airlines Benefits for Ground Handlers & Airports • Ticket sales • Drive traffic and volumes • Provides choice to customers who wish to begin • Testing can be done landside to avoid security and flying operational issues airside • Can potentially build the cost of testing into premium • Large-scale, outbound testing could see the reduction fares, encouraging premium customers back early in need for difficult to maintain physical distancing in • For non-premium customers, opportunity to integrate departures appointment booking into booking path to deliver • Improves the airbridge proposition seamless experience

9 Government Benefits

Complementary Solution to Quarantine • This helps provide a way forward that the public wants and can support – a safe speedy option to end the quarantine • This solution is a natural next step away from total quarantine • Through its enablement, both leisure and business travel can recommence safely • The purpose/focus of quarantine Is not compromised

10 Why Collinson & Swissport?

Strong Partnership Collinson Brings: • Collinson and Swissport have partnered for 6 years • Medical Expertise and Experience. In the past 12 under a JV model months, Collinson has: • Both are international businesses with global ✓ Answered 95,000 medical emergency calls footprints. This brings substantive understanding of ✓ Processed 60,000 medical cases what has worked in other countries. In particular, ✓ Delivered 3,000 aero-medical evacuations both can lean on substantive operations in APAC where the virus hit first, and which is generally seen • Partnership network expertise, partnering with 12m as to be leading the recovery. medical facilities across the globe - Both have strong relationships with airports and airlines Swissport Brings: - Both experts in understanding and delivering • Trusted provider to 318 airports worldwide and every traveller experiences UK airport • Scalability to deliver fast • Logistical strength & airport and airline customer connectivity

11 Together, we are now ready to deliver to the people of Britain the safe resumption of air travel.

Thank You

To: The Taskforce for Aviation Recovery From: Tropical Medical Bureau (TMB)

Re: TMB Submission to the Taskforce

Date: 24th June 2020

Overview:

The Tropical Medical Bureau (TMB) has been providing travel health support & services to the leisure, corporate and NGO travellers for over 30 years and we are fully aware of the social and economic impact Covid19 is having not only on the Irish economy but globally too. The TMB group in Ireland and the UK provides pre and post travel health services to 60,000 people travelling internationally.

Recognising that prior to the provision of a suitable and safe vaccine and/or an adequate and efficient treatment option a number of concerns will have a direct impact on international travel. A significant proportion of those wishing to travel have worries and concerns relating to their personal health and these need to be addressed to improve load factor and make aviation viable.

• Perceived safety on board o All departing travellers will be required to present certification confirming their current Covid-19 free status at check-in. This is achievable through a centralised national programme of rapid PCR testing, running separately to government resources, and incorporating suitable identification features imbedded within their certificate.

• Perceived smooth passage at point of entry o Provision of authorised and internationally acceptable current covid-19 clearance certification.

• Concern over Covid-19 related exposure / sickness at destination o Provision of a dedicated 24/7 health support line for all registered travellers to alleviate concerns relating to possible Covid-19 symptoms experienced while overseas.

• Concern over prolonged quarantine on arrival back into Ireland o Provision of rapid on-arrival PCR screening for all travellers associated with government health authority acceptance confirming that a negative viral test removes the requirement of any prolonged quarantine.

TMB are willing to offer its services, skills and experience to the Taskforce, either as advisors or consultants, pro-bono.

For further information or to discuss this in detail please contact me via email or phone.

Your sincerely,

Andrew Lewis CEO [email protected] 01-2715200 087-2057716 From: McAuliffe, Conor [ mailto:[email protected] ] Sent: Wednesday 17 June 2020 12:37 To: KEOGH Liam Subject: RE: IATA projections

Liam,

Thanks very much for this. Just some late thoughts on the Task Force initiative below

Shorter term needs

 To restore public confidence, scientific community endorsement of the health measures airports and airlines are putting in place make flying safe.  To ensure we have passengers to transport, lifting of travel restrictions on a reciprocal basis.  To ensure sustained recovery, flexible slot and scheduling policies beginning with a winter 2020/21 slot waiver  To accelerate recovery, extend existing government assistance, reduce/freeze taxes and charges

Longer term needs

 Government/industry partnership on regulatory/operational issues critical to a sustainable future including but not limited to the creation of a viable market in Sustainable Aviation Fuel. SAF are critical to achievement of the industry’s environmental goals and will help restore public confidence in the industry.  Integrated Tourist Board/Airline/Airport collaboration on destination marketing

Thanks,

Conor.